This area is not as clear as one would like. Currently, the only IRS guidance is Notice 2020-75, which does not contain any limitation on the type of income to which a PTE payment may be attributable. This 2020 Notice promised the issuance of regulations, which have not yet been issued. Until then, many tax professionals are taking the position that any PTE payment authorized by a state having a PTE regime generates an ordinary deduction that reduces ordinary income (or generates or increases an ordinary loss) reported on line 1 of a partnership or S corporation K-1.

Chuck Levun and I cover this topic, as well as many other at our two flow-through tax planning seminars:

• Forum – our advanced course with the most recent structuring techniques for closely held businesses

• Fundamentals of Flow-Through – an intermediate course that provides a solid foundation for using flow-through entities

Both are a fast-paced combination of exhibits and strategic/tactical applications presented in a transactional manner. And both include live Q&A with our faculty members – ensuring you get the answers you need to your real-world flow-through tax issues.

You can learn more and register here: www.taxforums.com/