Tax News

CCH (cch.taxgroup.com) reports:

A limited liability company (LLC), which is treated as a partnership for federal tax purposes may file a single aggregate composite Alabama 2007 personal income tax return on behalf of all of its nonresident partners/owners, including corporations and flow-through entities as well as"upper tier owner" individuals and entities. Ala. Code, §40-18-24.1(a) permits a subchapter K entity with income apportioned to Alabama to file a composite income tax return and make a composite tax payment on behalf of its nonresident owners and defines a "nonresident owner" to include an "owner other than an individual". Therefore, the statute clearly allows corporations and other pass-through entities to be included in a composite return. In addition, the statute does not distinguish between "direct" and "indirect" ownership of an entity as a condition for filing a composite return. Accordingly, an "indirect"upper-tier nonresident owner of a subchapter K entity may be included in the entity's composite return.
Revenue Ruling No. #07-001 , Alabama Department of Revenue, October 15, 2007, ¶201-242
Other References:
Explanations at ¶89-102