General Research & Analysis

Articles and Other Information

Nexus Issues

• • John A. Swain, “State Income Taxation of Out-of-State Corporate Partners,” 18 Chap. L. Rev. 211 (2014).
  • Walter Hellerstein, “Substance and Form in Jurisdictional Analysis: Corrigan v. Testa” (State Tax Notes) – June 13, 2016

State Taxation of Partnerships – Generally

• • Helen Hecht and Lila Disque, “A State Tax Administrator’s Perspective on Partnership Taxation” (Journal of Multistate Taxation and Incentives) – Aug. 2017

Pass-Through System – Complexity and Other Issues

• • Modernizing Partnership Taxation – Hamilton Project (Starting 2024)
  • Chris William Sanchirico and Reed Shuldiner, “Circular Partnerships,” Dec. 17, 2023 (See also here: TaxProf Blog)
  • Tax Policy Center, “A New Analysis Shows How Much Business Income Goes Untaxed,”   Jan. 11, 2022
  • Michael Love, “Where in the World Does Partnership Income Go? Evidence of a Growing Use of Tax Havens,” Columbia Law School (2021).
  • Andrea Monroe, “Making Tax Law Work: Improvisation and Forgotten Taxpayers in Partnership Tax,” Temple University Legal Studies Research Paper No. 2021-23, May 2021.
  • Martin J. McMahon, Jr., “Rethinking Taxation of Privately Held Businesses,” (ABA, The Tax Lawyer) – Winter 2016
  • Andrea Monroe, “What We Talk About When We Talk About Tax Complexity,”  5 Mich. Bus. & Entrepreneurial L. Rev. 193 (2016)
  • Andrea Monroe, “Taxing Reality: Rethinking Partnership Distributions,” 47 Loy. L.A. L. Rev. 657 (2014)
  • Andrea Monroe, “Integrity in Taxation: Rethinking Partnership Tax,” 64 Ala. Law Rev. 289 (2012)
  • Andrea Monroe, “Too Big to Fail: The Problem of Partnership Allocations,” 30 Va.Tax Rev. 465 (2011)
  • Andrea Monroe, “What’s in a Name: Can the Partnership Anti-Abuse Rule Really Stop Partnership Tax Abuse?,” 60 Case W. Res. L. Rev. 401 (2010)

Prior MTC Projects on Partnerships

• • Project on Treatment of Partnership Adjustments Under the Federal Centralized Partnership Audit Regime
  • 2004 – MTC Pass-Through Entity Compliance Work Group Report and Proposed Initiatives
  • Final Model Reporting Options for Nonresdient Members of Pass-Through Entities with Withholding Requirement – 2003
  • Original Proposal to Adopt Uniform Composite & Withholding Provisions – 1992

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