This document summarizes state tax issues related to partnerships, LLCs, and LLPs in Arizona. It discusses how these entities are classified and taxed at the state level, including how their income is apportioned among states. It also outlines some of the key state tax rules and traps related to property tax, multistate taxation, and transfers of assets between entities.
H.R.25 - Fair Tax Act of 2009
To promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States
H.R.25 - Fair Tax Act of 2009
To promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States
Anti Corruption Laws in Asia Pacific - Overview and ComparisonCharlotte Lang
Corruption issues can have severe consequences for a business, aside from long-term reputational damage, investigation and conviction entail significant costs in management time, penalties and civil claims. Corruption investigations can also have a serious impact on a company’s M&A prospects.
Anti-corruption law enforcement is now significantly stronger in Asia Pacific. All international companies, and their senior management, are under increasing pressure to implement proper procedures to prevent corrupt behaviours when operating in the region. Using intermediaries, doing business with state-owned enterprises, or simply dealing with local business practices, all raise anti-corruption concerns that are particularly relevant in Asia Pacific.
California as a Backdrop for Recent State Tax DevelopmentsCBIZ, Inc.
recent California income and franchise tax developments and how those developments compare and contrast with income and franchise tax laws in other states.
Business Law Training | State and Local Taxes: Key Developments That Will Aff...Quarles & Brady
Most businesses pay more state and local taxes than federal. This program will update you on some of the key developments in the state and local tax world that will affect your companies now and in the future. Topics include how changes in federal law will affect state taxes, the ongoing debacle over sales tax collection requirements, an explanation of how states are fundamentally changing their corporate taxes, and much more.
Advertising Tax Impact Accomplishments And The FutureAffiliate Summit
Discussion on the Advertising Tax by industry leaders that have played a key role in organizing industry advocates and educating legislators on the impact of state tax nexus legislation.
Brian Littleton, President / CEO, ShareASale.com (Twitter @Brianlittleton) (Moderator)
Karen Garcia, Partner, GTO Management (Twitter @karengarcia)
Beth Kirsch, Volunteer, Performance Marketing Alliance (Twitter @bethkirsch)
Melanie Seery, President, Affiliate Voice (Twitter @mellies)
Gale Finley of Sebaly Shillito + Dyer and Geoffrey Frazier, CPA, of Brady Ware discuss how to avoid unwanted surprises by learning what to look out for when going into other states to transact business.
Anti Corruption Laws in Asia Pacific - Overview and ComparisonCharlotte Lang
Corruption issues can have severe consequences for a business, aside from long-term reputational damage, investigation and conviction entail significant costs in management time, penalties and civil claims. Corruption investigations can also have a serious impact on a company’s M&A prospects.
Anti-corruption law enforcement is now significantly stronger in Asia Pacific. All international companies, and their senior management, are under increasing pressure to implement proper procedures to prevent corrupt behaviours when operating in the region. Using intermediaries, doing business with state-owned enterprises, or simply dealing with local business practices, all raise anti-corruption concerns that are particularly relevant in Asia Pacific.
California as a Backdrop for Recent State Tax DevelopmentsCBIZ, Inc.
recent California income and franchise tax developments and how those developments compare and contrast with income and franchise tax laws in other states.
Business Law Training | State and Local Taxes: Key Developments That Will Aff...Quarles & Brady
Most businesses pay more state and local taxes than federal. This program will update you on some of the key developments in the state and local tax world that will affect your companies now and in the future. Topics include how changes in federal law will affect state taxes, the ongoing debacle over sales tax collection requirements, an explanation of how states are fundamentally changing their corporate taxes, and much more.
Advertising Tax Impact Accomplishments And The FutureAffiliate Summit
Discussion on the Advertising Tax by industry leaders that have played a key role in organizing industry advocates and educating legislators on the impact of state tax nexus legislation.
Brian Littleton, President / CEO, ShareASale.com (Twitter @Brianlittleton) (Moderator)
Karen Garcia, Partner, GTO Management (Twitter @karengarcia)
Beth Kirsch, Volunteer, Performance Marketing Alliance (Twitter @bethkirsch)
Melanie Seery, President, Affiliate Voice (Twitter @mellies)
Gale Finley of Sebaly Shillito + Dyer and Geoffrey Frazier, CPA, of Brady Ware discuss how to avoid unwanted surprises by learning what to look out for when going into other states to transact business.
So, you have made a decision on the form of business entity, whether it is a corporation, LLC, or even a non-stock/non-profit. Like any well-oiled machine, it is not enough to set it up, now you have to keep it in working order. Corporate compliance is what you do after forming an entity to make sure the business remains in good standing with specific state law requirements. This webinar discusses how to maintain compliance with various state law requirements, including Delaware. Notice requirements and best practices on recording meetings will be reviewed, including which communications are protected by the attorney-client privilege and which ones are not. The importance of maintaining separate business and personal assets is analyzed. By-laws are analyzed, including how action is taken, whether by proxy, consents, resolutions, voter agreements, including the impact of technology on corporate action. Corporate compliance and ethics programs are discussed, including best practices; in particular, who should be a part of the reporting structure and who should not. Also discussed is whether the compliance program should be a stand-alone program or if it should be integrated into the normal business process of a company.
Part of the webinar series: CORPORATE & REGULATORY COMPLIANCE BOOT CAMP 2021 - PART 2
See more at https://www.financialpoise.com/webinars/
What advantages and disadvantages are there to illinois s corporations and ll...www.growthlaw.com
This memo describes the state tax, liability, and agency authority differences between Illinois business corporations with a subchapter S federal tax election and Illinois limited liability companies with the same election. It also discusses how the differences in entity type and location may relate to mergers and acquisitions.
Similar to Partnerships, LLCs and LLPs - May 2007 (20)
Essentials of Automations: Optimizing FME Workflows with ParametersSafe Software
Are you looking to streamline your workflows and boost your projects’ efficiency? Do you find yourself searching for ways to add flexibility and control over your FME workflows? If so, you’re in the right place.
Join us for an insightful dive into the world of FME parameters, a critical element in optimizing workflow efficiency. This webinar marks the beginning of our three-part “Essentials of Automation” series. This first webinar is designed to equip you with the knowledge and skills to utilize parameters effectively: enhancing the flexibility, maintainability, and user control of your FME projects.
Here’s what you’ll gain:
- Essentials of FME Parameters: Understand the pivotal role of parameters, including Reader/Writer, Transformer, User, and FME Flow categories. Discover how they are the key to unlocking automation and optimization within your workflows.
- Practical Applications in FME Form: Delve into key user parameter types including choice, connections, and file URLs. Allow users to control how a workflow runs, making your workflows more reusable. Learn to import values and deliver the best user experience for your workflows while enhancing accuracy.
- Optimization Strategies in FME Flow: Explore the creation and strategic deployment of parameters in FME Flow, including the use of deployment and geometry parameters, to maximize workflow efficiency.
- Pro Tips for Success: Gain insights on parameterizing connections and leveraging new features like Conditional Visibility for clarity and simplicity.
We’ll wrap up with a glimpse into future webinars, followed by a Q&A session to address your specific questions surrounding this topic.
Don’t miss this opportunity to elevate your FME expertise and drive your projects to new heights of efficiency.
Slack (or Teams) Automation for Bonterra Impact Management (fka Social Soluti...Jeffrey Haguewood
Sidekick Solutions uses Bonterra Impact Management (fka Social Solutions Apricot) and automation solutions to integrate data for business workflows.
We believe integration and automation are essential to user experience and the promise of efficient work through technology. Automation is the critical ingredient to realizing that full vision. We develop integration products and services for Bonterra Case Management software to support the deployment of automations for a variety of use cases.
This video focuses on the notifications, alerts, and approval requests using Slack for Bonterra Impact Management. The solutions covered in this webinar can also be deployed for Microsoft Teams.
Interested in deploying notification automations for Bonterra Impact Management? Contact us at sales@sidekicksolutionsllc.com to discuss next steps.
Accelerate your Kubernetes clusters with Varnish CachingThijs Feryn
A presentation about the usage and availability of Varnish on Kubernetes. This talk explores the capabilities of Varnish caching and shows how to use the Varnish Helm chart to deploy it to Kubernetes.
This presentation was delivered at K8SUG Singapore. See https://feryn.eu/presentations/accelerate-your-kubernetes-clusters-with-varnish-caching-k8sug-singapore-28-2024 for more details.
Key Trends Shaping the Future of Infrastructure.pdfCheryl Hung
Keynote at DIGIT West Expo, Glasgow on 29 May 2024.
Cheryl Hung, ochery.com
Sr Director, Infrastructure Ecosystem, Arm.
The key trends across hardware, cloud and open-source; exploring how these areas are likely to mature and develop over the short and long-term, and then considering how organisations can position themselves to adapt and thrive.
Generating a custom Ruby SDK for your web service or Rails API using Smithyg2nightmarescribd
Have you ever wanted a Ruby client API to communicate with your web service? Smithy is a protocol-agnostic language for defining services and SDKs. Smithy Ruby is an implementation of Smithy that generates a Ruby SDK using a Smithy model. In this talk, we will explore Smithy and Smithy Ruby to learn how to generate custom feature-rich SDKs that can communicate with any web service, such as a Rails JSON API.
Elevating Tactical DDD Patterns Through Object CalisthenicsDorra BARTAGUIZ
After immersing yourself in the blue book and its red counterpart, attending DDD-focused conferences, and applying tactical patterns, you're left with a crucial question: How do I ensure my design is effective? Tactical patterns within Domain-Driven Design (DDD) serve as guiding principles for creating clear and manageable domain models. However, achieving success with these patterns requires additional guidance. Interestingly, we've observed that a set of constraints initially designed for training purposes remarkably aligns with effective pattern implementation, offering a more ‘mechanical’ approach. Let's explore together how Object Calisthenics can elevate the design of your tactical DDD patterns, offering concrete help for those venturing into DDD for the first time!
Securing your Kubernetes cluster_ a step-by-step guide to success !KatiaHIMEUR1
Today, after several years of existence, an extremely active community and an ultra-dynamic ecosystem, Kubernetes has established itself as the de facto standard in container orchestration. Thanks to a wide range of managed services, it has never been so easy to set up a ready-to-use Kubernetes cluster.
However, this ease of use means that the subject of security in Kubernetes is often left for later, or even neglected. This exposes companies to significant risks.
In this talk, I'll show you step-by-step how to secure your Kubernetes cluster for greater peace of mind and reliability.
Neuro-symbolic is not enough, we need neuro-*semantic*Frank van Harmelen
Neuro-symbolic (NeSy) AI is on the rise. However, simply machine learning on just any symbolic structure is not sufficient to really harvest the gains of NeSy. These will only be gained when the symbolic structures have an actual semantics. I give an operational definition of semantics as “predictable inference”.
All of this illustrated with link prediction over knowledge graphs, but the argument is general.
Epistemic Interaction - tuning interfaces to provide information for AI supportAlan Dix
Paper presented at SYNERGY workshop at AVI 2024, Genoa, Italy. 3rd June 2024
https://alandix.com/academic/papers/synergy2024-epistemic/
As machine learning integrates deeper into human-computer interactions, the concept of epistemic interaction emerges, aiming to refine these interactions to enhance system adaptability. This approach encourages minor, intentional adjustments in user behaviour to enrich the data available for system learning. This paper introduces epistemic interaction within the context of human-system communication, illustrating how deliberate interaction design can improve system understanding and adaptation. Through concrete examples, we demonstrate the potential of epistemic interaction to significantly advance human-computer interaction by leveraging intuitive human communication strategies to inform system design and functionality, offering a novel pathway for enriching user-system engagements.
State of ICS and IoT Cyber Threat Landscape Report 2024 previewPrayukth K V
The IoT and OT threat landscape report has been prepared by the Threat Research Team at Sectrio using data from Sectrio, cyber threat intelligence farming facilities spread across over 85 cities around the world. In addition, Sectrio also runs AI-based advanced threat and payload engagement facilities that serve as sinks to attract and engage sophisticated threat actors, and newer malware including new variants and latent threats that are at an earlier stage of development.
The latest edition of the OT/ICS and IoT security Threat Landscape Report 2024 also covers:
State of global ICS asset and network exposure
Sectoral targets and attacks as well as the cost of ransom
Global APT activity, AI usage, actor and tactic profiles, and implications
Rise in volumes of AI-powered cyberattacks
Major cyber events in 2024
Malware and malicious payload trends
Cyberattack types and targets
Vulnerability exploit attempts on CVEs
Attacks on counties – USA
Expansion of bot farms – how, where, and why
In-depth analysis of the cyber threat landscape across North America, South America, Europe, APAC, and the Middle East
Why are attacks on smart factories rising?
Cyber risk predictions
Axis of attacks – Europe
Systemic attacks in the Middle East
Download the full report from here:
https://sectrio.com/resources/ot-threat-landscape-reports/sectrio-releases-ot-ics-and-iot-security-threat-landscape-report-2024/
Smart TV Buyer Insights Survey 2024 by 91mobiles.pdf91mobiles
91mobiles recently conducted a Smart TV Buyer Insights Survey in which we asked over 3,000 respondents about the TV they own, aspects they look at on a new TV, and their TV buying preferences.
Smart TV Buyer Insights Survey 2024 by 91mobiles.pdf
Partnerships, LLCs and LLPs - May 2007
1. Partnerships, LLCs and LLPs:
State Tax Issues
Presented by
Mike Galloway
Member
Bancroft Susa & Galloway, PC
www.arizonatax.com
Bancroft Susa & Galloway
A PROFESSIONAL CORPORATION
3. Ha Ha!
A. What is the difference between
Osama Bin Laden and a
lawyer?
A. Bin Laden has some good
qualities.
4. Top 10 Reasons Why Lawyers
Should Replace Lab Rats
1. There is an endless supply.
2. Lab assistants don’t get attached to them.
3. It’s more fun to shave and stick needles in lawyers.
4. There are some things rats just won’t do.
5. It’s fun to dispose of them when you’re through.
6. It’s not “inhumane” treatment, when it comes to
lawyers
7. No one cares when a lawyer squeals.
8. We’ve seen what happens when they are allowed
to breed in the wild.
9. Lawyers belong in cages.
10. Animal rights activists don’t care if you torture
lawyers.
5.
6. In General
• An LLC will be classified for Arizona
income tax purposes as either
– A partnership
– A corporation (including an S), or
– A disregarded entity
depending on its classification for federal
income tax purposes under Treas. Reg.
§§ 301.7701-1 etc.
7. Choosing The Right Tax
• If the LLC is classified as a partnership,
it will report its income to Arizona on
Form 165
• If classified as a corporation, on Form
120
• If classified as a S Corporation, on Form
120S
• If a single member LLC is disregarded
as an entity separate from its owner, on
the Arizona tax return of its owner
8. The Partnership Rules
• The old law — Arizona had its own
independent partnership tax code
• Now — Arizona taxable income "piggy
backs" from federal income — the
federal "flows through" to the state
– Federal taxable income equals
Arizona gross income
– Look at the tax return
9. The Partnership Rules
• Add or subtract the separate computation items
of A.R.S. § 43-1412
• Make the individual statutory additions and
subtractions
• Allocate this amount to the respective K-1s
– Arizona K-1s make net adjustments
– Non-residents only report Arizona source
income
• Report these amounts on the partner’s
individual tax return
• Apply the appropriate individual state tax rate
• Apply the applicable individual state tax credits
10. Who Is Subject To Taxation?
• Generally if you are doing business in a
particular state
• A state is subject to the limitations
imposed by the Due Process and
Commerce Clauses of the U.S.
Constitution
– Quill says there must be physical
presence
• If an LLC is subject to tax in more than
one state, those states must apportion
the tax burden among themselves
11. Arizona Apportionment Rules
They are generally based on the following
formula:
Arizona Property + Arizona Payroll + o Arizona Sales Total Income
2 o
Total Property Total Payroll Total Sales X p/s = taxable
income by
4 Arizona
– This is the current Arizona version of the
traditional UDITPA three factor formula
12. Apportionment Is Based
On Two Concepts
• Business Income
• Non Business Income
– Business income arises “from
transactions and activity in the regular
course of the taxpayers business . . .”
– Non business income is “all income
other than business income”
13. Apportionment Is Based
On Two Concepts
• Business income is apportioned
among the states where the
taxpayer engages in business
• Non business income is generally
allocated to the one state where the
income is generated
14. Non Business Income
• Non business income consists of:
– Rents
– Royalties
– Capital Gains
– Patent Royalties
– Copyright Royalties
– Dividends
– Interest
15. Business Income
• Business income consists of all income
arising from the taxpayer’s regular
business activity
• It is apportioned among all of the states
where the taxpayer is doing business
based on the percentage of three factors
from the above formula:
– The property factor
– The payroll factor
– The sales factor
16. The Property Factor
• The percent of the taxpayer’s total
property that is in Arizona
– Does not include intangible property
– The value of the property is its original
cost as adjusted for improvements and
dispositions but not depreciation
– If leased, the value is eight times the
annual rent
– Property used to produce nonbusiness
income is nonbusiness
17. The Payroll Factor
• The percent of the taxpayer’s total
payroll that is in Arizona
– Only what is paid to employees, not
independent contractors
– Applies to services performed entirely or
mostly in Arizona
18. The Sales Factor
• The percent of the taxpayer’s total
sales that are in Arizona
• Sales includes sales but also:
– Services
– Leasing
– Licensing
– Etc.
19. There are different rules for sales of
tangible and intangible property
• Tangible Personal Property
– Arizona uses the “destination” rules for sourcing
TPP
– A sales is Arizona source if it is shipped into
Arizona
– The “throwback” rules have been repealed
• Intangible Personal Property
– It is Arizona source if:
• The income producing activity is in Arizona, or
• Most of the income producing activity is in
Arizona
• See Heller Western
20. Miscellaneous
• There are rules that allow alternative
methods or factors to be used
• Many states, although not Arizona (with
one exception), have special
apportionment formulas for certain
industries (banks, railroads, publishing)
21. In Summary
• An LLC will be taxed by Arizona under the federal
rules with certain Arizona adjustments
• An LLC or group of LLCs can be taxed by all of the
states in which they are doing business or
physically present
• An LLC or group of LLCs can be taxed by states
where they are not doing business or physically
present if one of the LLCs is doing business or
physically present and the others are unitary
• The total income of the LLC or LLC group will be
apportioned among the states where they are
subject to tax
22. The Corporation Rules
• The old law—Arizona had its own
independent corporate tax code
• Now—Arizona taxable income “piggy
backs” from federal income—the federal
“flows through” to the state
– Federal taxable income equals Arizona
gross income
23. The Corporation Rules
• Make the statutory additions and
subtractions
• The result at this point is Arizona taxable
income
• Apply the corporate income tax rate of
6.968% of the taxable income
• Apply the applicable corporate state tax
credits
• Be aware of special state rules for certain
types of corporations
24. The Unitary Concept
• Even though, for example, only one LLC may
be physically present or doing business in
Arizona, related entities may contribute to the
income produced in Arizona.
• Under the unitary theory, Arizona may tax the
total (apportioned) income of all of the related
entities.
• The related entities must be unitary—effectively
operating as a single unit (an “organic whole’)
for business purposes.
• In Arizona, the test is “operational integration”
– Contrast with California’s “functional integration”
• Arizona has a big regulation on point.
25. The Unitary Concept
• In Arizona, the limit on taxing is “water’s
edge”
– Contrast with California’s “world wide”
combined reporting.
26. The Individual Rules
• Same as the partnership, except:
– Federal adjusted income equals Arizona
gross income
• Make the individual statutory additions
and subtractions
• Report this amount on the individual tax
return
• Apply the appropriate individual state tax
rate
• Apply the applicable individual state tax
credits
27. State Tax Traps
• City Speculative Builder Tax
• Transfers of Assets
• Intercompany Leasing
• Property Tax Exemptions
• Property Tax Affidavits of Value
• Successor Liability
• Multistate Taxation
28. Partnerships, LLCs and LLPs:
Organization And Operation In Arizona
Presented by
Mike Galloway
Member
Bancroft Susa & Galloway, PC
www.arizonatax.com
Bancroft Susa & Galloway
A PROFESSIONAL CORPORATION