Entity Structure and Financial Independence
Entity structure crosses federal classification, state holding-entity, and entity-capacity systems. This page keeps those evidence rails separate and does not turn a legal or tax field into an economic outcome.
/* Not legal advice. This page is research, not compliance guidance. */ /* */
Entity structure crosses three different rule systems
Federal classification, state holding-entity rules, and entity-capacity records answer different questions; none alone establishes the economics or outcome of a structure.
The federal rail asks how a named eligible entity, subsidiary, or owner is treated under the cited federal classification rule. The state holding-entity rail asks which entity types, activities, tests, treatments, filing obligations, effective periods, and stated limits appear in a jurisdiction's cited rule. The entity-capacity rail asks whether a named kind of entity may occupy a particular role or satisfy an assignment or admission predicate under the cited state law. One rail cannot answer for another.
The task here is to trace an entity stack without turning its labels into proof of economics, privacy, or independence. Start with the question the record actually answers. Use the federal cells for the named classification, subsidiary-treatment, or shareholder-eligibility question. Use the state holding-entity fields for the named jurisdiction, regime, activity, treatment, filing rule, period, or non-reach statement. Use the capacity fields for the named director, general-partner, manager, member, assignment, admission, or trust-as-member predicate. A permission in one system does not supply a classification or treatment in another, and a result for one entity type does not fill a field for another.
A classification may determine how a named federal rule treats an entity for its stated purpose. A state field may identify a regime, activity test, treatment, filing obligation, period, or non-reach statement. A capacity field may identify a role an entity may occupy. None of those statements establishes net worth, available cash, solvency, beneficial economics, or financial independence.
The federal entity-classification reference carries the federal rail. The state entity-tax reference carries the holding-tax family. The business-formation hub supplies the entity-capacity context. These links keep the systems connected without merging their predicates.
What the federal default-classification cells verify
The cited cells establish only the named default treatment, effects and exceptions, and eligible-entity scope or election context for the federal entity-owned single-member LLC classification question.
The three federal cells belong to one classification question, but each carries a different boundary. The first covers the cited default for a domestic eligible entity with one owner. The second covers the cited effects and exceptions associated with disregarded treatment. The third covers the eligible-entity scope and election context. The cells travel together here because the question needs all three boundaries; their contents are not collapsed into one paraphrased rule.
Default treatment is not a statement about every federal or state purpose. Effects and exceptions must remain with the cell that states them. Eligible-entity scope and election context do not establish that a particular entity made an election or satisfied a requirement outside the cited field. A state role, filing obligation, or holding-tax treatment cannot substitute for any of these federal predicates.
The exact cell statements follow. Each value remains attached to the US-federal jurisdiction, LLC entity type, field, variant, source, and checked date recorded with that cell.
- Default treatment: A domestic eligible entity with a single owner is disregarded as an entity separate from its owner by default unless the entity elects otherwise, subject to the paragraph (b)(3) existing-entity exception. source
- Effects and exceptions: A single-owner noncorporate business entity is generally disregarded, but the regulation treats it separately for listed tax liabilities, employment tax, backup withholding owner attribution, self-employment tax treatment, specified excise-tax purposes, section 6038A reporting, and disregarded-payment rules. source
- Eligible-entity scope and election context: An eligible entity may elect classification; a single-owner eligible entity may elect association treatment or disregarded treatment, and the default classification applies only when no election is made. source
What the QSub and shareholder-eligibility cells verify
The QSub cells establish their named definition and treatment boundary, while the shareholder-eligibility cells establish the cited owner-classification constraint; neither is a rule for every subsidiary or owner.
The QSub group contains three distinct federal statements: definition conditions, federal tax treatment, and regulatory-treatment exceptions. The definition cell identifies the named conditions within its statute. The treatment cell states the cited federal treatment. The exceptions cell preserves the separate regulatory boundary. A statement in one variant does not erase a condition or exception carried by another.
The shareholder-eligibility group answers a different owner-classification question. Its cells address disregarded-LLC stock-owner attribution, shareholder-of-record and entity-owner corroboration, and the statutory shareholder bar. They do not establish that every LLC owner, subsidiary, shareholder, or entity arrangement has the same result. They also do not turn an entity-capacity permission under state law into federal shareholder eligibility.
The six exact statements remain divided into the two federal questions below.
- QSub definition conditions: A QSub is a domestic corporation that is not an ineligible corporation, 100 percent of whose stock is held by an S corporation, and for which the S corporation elects QSub treatment. source
- QSub federal tax treatment: Except as regulations provide, a QSub is not treated as a separate corporation and its assets, liabilities, income, deductions, and credits are treated as those of the S corporation; if QSub status ceases, the corporation is treated as a new corporation acquiring all assets and assuming all liabilities immediately before cessation. source
- QSub regulatory-treatment exceptions: The regulation ignores separate QSub existence generally, but excepts banks, certain tax liabilities/refunds, employment taxes, specified excise taxes and related registration/credit/payment/reporting items, and information returns. source
- Disregarded-LLC stock-owner attribution: IRS Form 2553 instructions attribute stock held by a disregarded single-member LLC to the LLC owner for consent purposes; the owner, not the disregarded LLC itself, must be eligible to be an S corporation shareholder. source
- Shareholder-of-record and entity-owner corroboration: The regulation repeats the non-individual and nonresident-alien shareholder bars, treats the beneficial owner rather than a nominee as shareholder, treats a partnership beneficial owner as disqualifying, and separately attributes family-member ownership through disregarded entities only for the family-counting rule. source
- Statutory shareholder bar: Section 1361 bars an S corporation from having, as a shareholder, a non-individual other than an estate, a qualifying trust, or a qualifying organization, and also bars nonresident alien shareholders. source
What state holding-entity rules verify
Each state row establishes only its cited rule scope, covered entity type, qualifying activity or test, treatment, filing rule, effective period, or stated non-reach.
The state family is organized by jurisdiction and named tax-regime variant. Eight fields travel together for each variant: covered entity types, qualifying activities, the qualifying-test text, tax regime, treatment, filing rule, effective period, and stated non-reach. A jurisdiction may carry more than one regime variant, so a value from one variant cannot be promoted into a statewide statement about every entity or obligation.
A covered-entity field identifies only the entities within the cited rule's scope. A qualifying activity or test identifies the rule's stated threshold or predicate. Treatment reports the treatment established by that source. A filing rule reports an obligation, not how long an agency keeps a submission. Effective period dates the cited rule boundary. A non-reach field preserves what the source says falls outside that variant; it is not a general exemption from every other state or federal rule.
Read the fields as a sequence without turning them into one conclusion. Scope identifies the named reach of the rule; activity and test fields identify its cited predicates; treatment and filing fields state separate consequences or duties; the period and non-reach fields bound those statements. None of them establishes where an operator's assets are located, what remedy applies to those assets, or what economic effect the rule has for a particular structure.
The comparison retains unknown boundaries. When the captured primary sources did not settle a field, the table shows the unknown state and its visible explanation rather than borrowing a value from another regime, jurisdiction, field, or secondary summary. The affected comparison remains incomplete at that exact position.
The state entity-tax reference provides the broader state context. The table below is limited to the holding-entity family on this page and does not state an economic result for an operator.
| Jurisdiction / regime | Covered entity types | Qualifying activities | Qualifying test | Tax regime | Treatment | Filing rule | Effective period | Stated non-reach |
|---|---|---|---|---|---|---|---|---|
| AK 1/4 | An LLC follows its federal classification and files under the corporate instructions when federally characterized as a corporation.source | Alaska-source income includes stocks, bonds, notes, bank deposits, other intangibles, rents, and royalties when the stated situs rules are met.source | For water's-edge combined reporting, the statute excludes stated shares of qualifying foreign-corporation dividends and royalties, subject to the unitary-payment test.source | Alaska imposes corporation net income tax on every corporation's taxable income derived from Alaska sources.source | Qualifying foreign-corporation dividends and royalties receive statutory exclusions from taxable income; Chapter 20 states no general holding-entity exemption.source | A federally corporate LLC files under the corporate instructions, and the Alaska return is due in the month following the federal due date.source | The current Form 6000 tax-rate table identifies its operative period as tax years beginning on or after August 26, 2013.source | Interest earned on property in Alaska does not by itself establish a taxable or business situs in Alaska.source |
| AK 2/4 | The add-on can reach a federally corporate LLC that satisfies the incorporated IRC § 542 personal-holding-company definition.source | The incorporated personal-holding-company-income definition begins with dividends, interest, specified royalties, and annuities.source | IRC § 542 requires both the 60% income test and the stock-ownership test; Alaska Form 6000 adopts that definition for the add-on.source | Alaska assesses a personal-holding-company tax in addition to ordinary corporation tax and uses the Alaska statutory rate.source | A qualifying personal holding company calculates ordinary Alaska corporation tax and a separate add-on reported on Schedule E.source | A personal holding company reports the add-on on Form 6000 Schedule E, line 4, with apportionment when appropriate.source | No effective or sunset period for the current Alaska personal-holding-company add-on was stated in complete Chapter 20 or the current Form 6000 instructions.source | The incorporated definition excludes the listed exempt, banking, insurance, surety, and foreign corporations; further specialized exceptions follow in IRC § 542(c).source |
| AK 3/4 | An LLC follows its federal tax status; this branch reaches one characterized as a corporation with an S election.source | The incorporated passive-investment-income definition names royalties, rents, dividends, interest, and annuities, subject to statutory exceptions.source | IRC § 1375 applies when an S corporation has accumulated earnings and profits at year end and passive investment income exceeds 25% of gross receipts.source | Alaska imposes the incorporated excess-net-passive-income tax on an S corporation at the stated Alaska marginal rate.source | Although ordinary pass-through items are not taxed to the S corporation, Alaska separately taxes excess net passive income at the stated corporate rate.source | An Alaska S corporation files Form 6000 with its federal Form 1120-S pages and reports excess-net-passive-income tax on Schedule E line 6 when applicable.source | No Alaska effective or sunset period for the excess-net-passive-income add-on was stated in complete Chapter 20 or the current Form 6000 instructions.source | The conditional text does not impose the tax without both year-end accumulated earnings and profits and passive receipts above 25% of gross receipts.source |
| AK 4/4 | Chapter 70 defines business by the entity's activity and defines person to include firms, partnerships, associations, corporations, and other acting units.source | No general holding- or passive-entity carve-out was located in complete Chapter 70; the definition turns on activity for financial benefit in exchange for services, goods, or other property.source | Chapter 70 states no general holding-company test; its business definition and a narrow educational investment-club exemption delimit the regime.source | A person engaging in business in Alaska must first obtain a business license and pay the statutory annual fee.source | The license-fee statute reaches a person engaging in statutory business, and complete Chapter 70 contains no general holding- or passive-entity carve-out.source | A person must apply on the prescribed form, obtain the license, and pay the fee before engaging in business in Alaska.source | No effective or sunset period for the current business-license fee was stated in complete Chapter 70.source | Chapter 70 exempts the activities of a qualifying educational investment club; that narrow exemption does not state a general holding-LLC exclusion.source |
| AL 1/3 | The chapter separately defines corporation, limited liability entity, and disregarded entity so that LLCs in each stated federal tax classification can fall within the privilege-tax scope.source | The electing-family-LLE definition covers stated passive receipts and assets, including interest, dividends and distributions, rents and license fees, royalties, securities, funds, and appreciation assets.source | The classification requires the stated family ownership, annual election, and either the 90% gross-receipts test or the 90% assets test, including every listed computation rule.source | The annual Alabama Business Privilege Tax reaches every corporation, limited liability entity, and disregarded entity doing business in Alabama or organized, qualified, or registered there.source | A qualifying electing family limited liability entity remains subject to Business Privilege Tax but receives a separate statutory maximum-tax treatment.source | Every taxpayer files a privilege-tax return for each taxable year in which it is subject to the tax.source | The current rate provision applies to taxable years beginning after December 31, 1999.source | The family treatment is limited to a Subchapter K limited liability entity; the separate title-holding maximum expressly applies only to a not-for-profit corporation.source |
| AL 2/3 | Alabama's corporation definition includes any entity classified as an association taxable as a corporation for federal income-tax purposes.source | The corporate-income calculation allows specified dividend deductions when the taxpayer owns greater than 20% of the distributing corporation by vote or value.source | The operative deduction requires greater-than-20% stock ownership by vote or value and enumerates the dividend categories allowed.source | An LLC classified as an association taxable as a corporation for federal income-tax purposes falls within Alabama's corporation definition and corporate-income-tax levy.source | A corporation-classified holding LLC remains within corporate income tax, while the statutory deduction changes the tax base for the listed dividends when the ownership test is met.source | Each corporation subject to chapter 18 income tax files a return for each taxable year stating its gross-income items and allowed deductions and credits.source | The complete corporate-income provisions state no effective or sunset period for the current levy or the dividend deduction.source | The dividend deduction is limited by its greater-than-20% ownership test and the enumerated dividend categories in Ala. Code § 40-18-35(a)(7).source |
| AL 3/3 | The election is available to Alabama S corporations and Subchapter K entities; the latter definition includes partnership-classified LLCs and excludes single-member LLCs.source | No holding- or passive-activity carve-out is stated in the elective pass-through-entity tax section or its tax-base cross-references.source | The elective pass-through-entity tax provisions state no receipts, assets, ownership, or other holding-company qualification test.source | A qualifying Alabama S corporation or Subchapter K entity may elect the Alabama pass-through-entity tax; an electing entity pays the tax under the stated base and apportionment rules.source | No holding- or passive-entity exemption, deduction, or alternative tax treatment is stated for the elective pass-through-entity tax.source | The statute states the election and revocation filing deadlines, approval requirements, continuing-election rule, and the timely-return method for tax years beginning in 2025.source | The elective pass-through-entity tax election is available for tax years beginning on or after January 1, 2021.source | The elective pass-through-entity tax provisions state no holding-income or holding-entity limit to the regime's scope.source |
| AR 1/4 | An LLC and its members are classified and taxed for Arkansas income-tax purposes as they are for federal income-tax purposes, except when the LLC elects Arkansas PTE tax.source | The corporate instructions exempt dividends from directly owned subsidiaries when ownership is 80% or greater.source | The stated test is direct ownership of 80% or greater in the subsidiary paying the dividend.source | For tax years beginning on or after January 1, 2024, Arkansas imposes annual income tax on a domestic corporation's entire net income from carrying on or doing business.source | A corporation-classified LLC remains in the corporate-income-tax regime, but dividends from an 80%-or-greater directly owned subsidiary are exempt.source | Arkansas corporate income-tax returns are due on the fifteenth day of the fourth month following the end of the tax year.source | The current domestic-corporation provision applies to tax years beginning on or after January 1, 2024.source | The exemption is limited to qualifying dividends; the instructions separately require taxable interest, gross rents, and gross royalties to be entered.source |
| AR 2/4 | The franchise-tax chapter's corporation definition expressly includes domestic and foreign, active and inactive LLCs organized in or qualified under Arkansas law.source | No holding-company, passive-income, dividend, royalty, interest-income, or investment-income carve-out was located in the searched franchise-tax materials.source | No holding-activity, holding-income, ownership-percentage, income-percentage, or asset-percentage qualification test was located for this tax.source | Unless exempted under § 26-54-105, every entity within the chapter's corporation definition files an annual report and pays annual franchise tax.source | An LLC is taxed under the universal annual-franchise-tax rule and pays the minimum franchise tax; no separate holding-company treatment was located.source | LLCs may file through the Secretary of State website or on paper, and all companies must comply with the May 1 due date.source | The current form is the 2026 annual LLC franchise-tax report and states a May 1, 2026 due date.source | The current LLC report identifies only nonprofit/federally income-tax-exempt corporations and Uniform Partnership or Limited Partnership Act organizations as exempt.source |
| AR 3/4 | The business-entity definition includes an LLC, partnership, or federal Subchapter S corporation engaged for profit and required to file an Arkansas return.source | The regime gives net capital gain a half-rate and requires an affected entity with an interest in another affected entity to subtract or add back its distributive share of the lower-tier entity's Arkansas-source income or loss.source | An affected business entity with net capital gain applies 50% of the ordinary rate to that gain.source | The elective PTE tax permits a partnership, Sub-S corporation, or LLC to file one return and pay Arkansas income tax for all owner-members.source | The electing entity remains subject to PTE tax, but its net capital gain is taxed at half the rate applied to its other taxable income.source | Owners holding more than 50% of voting power make the election by the extended return due date; Form AR1100PET is due on the fifteenth day of the fourth month.source | Act 362's elective PTE provisions apply to tax years beginning on or after January 1, 2022.source | The half-rate treatment is confined to net capital gain; the main levy applies to the affected entity's net taxable business income.source |
| AR 4/4 | The line applies to S corporations; Arkansas's LLC classification statute reaches an LLC classified and taxed as an S corporation for federal income-tax purposes.source | The instructions identify passive investment income by the federal IRC § 1362(d)(3)(C) cross-reference; no broader activity label is inferred.source | The tax requires C-corporation earnings and profits at year-end, passive investment income above 25% of gross receipts, and taxable income; the worksheet then compares lines 2 and 3.source | Arkansas taxes an S corporation's excess net passive income in the federal manner and reports the entity-level amount on line 6 of Form AR1100PET.source | A qualifying S-corporation-classified LLC pays a separate entity-level tax on excess net passive income and reports it on AR1100PET line 6.source | Enter the tax on AR1100PET line 6 and attach a schedule showing the computation in the worksheet's line 1-11 format.source | The 2025 instructions identify 4.3% as the 2024 rate for this line-6 tax.source | The line does not apply if the corporation has always been a Subchapter S corporation; the instructions also require all three listed liability conditions.source |
| AZ 1/2 | For Title 43, an LLC follows its federal classification and is taxed as a partnership, corporation, or disregarded entity.source | The corporate base subtracts dividends from a corporation controlled at 50% or more and dividend income from foreign corporations.source | The domestic dividend subtraction requires at least 50% direct or indirect voting-stock ownership or control; foreign dividends are separately subtracted.source | Arizona imposes corporate income tax on the entire Arizona taxable income of every corporation, subject to stated exemptions.source | Controlled-corporation dividends are subtracted when computing Arizona corporate taxable income.source | A corporation subject to Title 43 must file an Arizona return even when it has no federal taxable income.source | A.R.S. § 43-1111 states the current rate for taxable years beginning after December 31, 2016.source | The domestic-corporation dividend subtraction uses a 50%-or-more voting-control threshold.source |
| AZ 2/2 | The election covers a business federally treated as a partnership or S corporation; an LLC follows its federal Title 43 classification.source | No holding- or passive-activity carveout was located in the complete Chapter 10 and Chapter 14 search.source | No holding- or passive-entity qualifying test was located in the complete Chapter 10 and Chapter 14 search.source | Eligible owners of a federally partnership- or S-corporation-treated business may elect Arizona entity-level income tax.source | The elective PTE provisions state no separate holding- or passive-entity treatment.source | The election is made on the business return, and an electing partnership or S corporation pays estimated tax as necessary.source | The entity-level election applies to taxable years beginning after December 31, 2021.source | The election excludes income attributable to ineligible owner types and individual, estate, or trust owners who opt out.source |
| CA 1/6 | Covers domestic and foreign LLCs not taxable as corporations, including disregarded single-member LLCs; LLCs exempt under § 23701h or § 23701x as title-holding companies are excluded.source | A full-text search of R&TC Chapter 10.6 found no holding-company or passive-entity carve-out from the annual tax for an LLC with ordinary taxable owners.source | Chapter 10.6 states no holding or passive carve-out from the annual tax for an LLC with ordinary taxable owners, so there is no qualifying test; a full-text search found none.source | California imposes an annual tax for the privilege of doing business on each LLC doing business in the state and on each LLC whose articles are accepted or registration issued by the Secretary of State.source | The annual tax reaches each LLC doing business in California and each LLC organized or registered there; Chapter 10.6 states no carve-out for holding or passive LLCs with ordinary taxable owners.source | An LLC exempt under § 23701 files the exempt-organization annual return (§ 23772, with a small-receipts exception); other LLCs, including disregarded ones, file the LLC return under § 18633.5.source | The annual tax applies to taxable years beginning on or after January 1, 1997; § 17941 was last amended effective July 13, 2026.source | The only exclusion, § 17941(d), covers LLCs exempt under § 23701h or § 23701x as title-holding companies; that exemption is limited to entities owned by exempt organizations and does not reach other LLCs.source |
| CA 2/6 | Covers every LLC subject to the § 17941 tax, so domestic and foreign LLCs not taxable as corporations, including disregarded single-member LLCs, but not LLCs exempt under § 23701h or § 23701x.source | Carve-out: income or gain allocated, and distributions made, to an LLC as a member or economic-interest holder of another LLC when attributable to income already subject to the fee.source | Allocations and distributions from another LLC are excluded from total income only if directly or indirectly attributable to income subject to the fee; the provision sets no numeric threshold.source | Every LLC subject to the § 17941 annual tax also pays an annual fee in tiers measured by its total income from all sources derived from or attributable to California (§ 17942(a)).source | Total income, the measure of the fee, excludes allocations and distributions an LLC receives as member or economic-interest holder of another LLC when attributable to income already subject to the fee.source | The fee is due with the LLC return required by § 18633.5 and must be estimated and paid by the 15th day of the sixth month of the taxable year; a disregarded LLC's return must show its §§ 17941-17942 liability.source | § 17943 applies the § 17942 fee amounts to the taxable year beginning January 1, 2001 and later years; § 17942 was last amended effective September 30, 2008.source | Excluded only if attributable to income already subject to the fee; sales-factor exclusions do not apply; FTB counts non-LLC pass-through shares; the § 17941(d) title-holding exclusion is limited to exempt-owned entities.source |
| CA 3/6 | Covers every corporation not expressly exempt and, for this tax, any LLC classified as an association, following its federal classification; S corporations stay subject to Chapters 2 and 3 at their own rate.source | Covers holding stock or bonds of other corporations and receiving and disbursing dividends and interest (§ 23102), and alien corporations trading securities for their own account (§ 23040.1).source | § 23102: holds stock or bonds, no trading, only receives and disburses dividends and interest; § 23040.1(c): non-dealer alien corporation trading for its own account as described in (a)(2). No numeric threshold.source | California's franchise tax, measured by net income and not less than the § 23153 minimum tax, reaches corporations doing business in the state; an LLC is within it only if classified as an association.source | § 23102: a non-trading stock or bond holder only receiving and disbursing dividends and interest is not doing business for Ch. 2. § 23153: unless expressly exempted, incorporated, qualified or doing-business corporations owe minimum tax.source | Part 11 taxpayers file a return by the 15th day of the fourth month after year-end (§ 18601(a)); exempt organizations file § 23772 returns; no return rule specific to § 23102 holding corporations was found.source | The § 23151(f)(2) measure applies to taxable years beginning on or after January 1, 2000 and the § 23101(b) tests from 2011; § 23102 was last amended in 1951; § 23040.1 was last amended effective January 1, 2002.source | § 23102 does not reach corporations that trade securities or do more than receive and disburse dividends and interest, and is limited to this chapter; § 23040.1 excludes dealers, and (b)(2) bars (a)(2) for other California income.source |
| CA 4/6 | Covers every corporation other than a bank, plus associations, business trusts and other entities classified as associations, so an LLC classified as an association; S corporations are taxed at their own rate.source | Carve-outs: a corporate partner's share of an investment partnership's interest, dividends and securities gains, and an alien corporation's income from trading securities for its own account.source | Partnership income qualifies only as the corporation's sole California income, with no part in, or unitary tie to, managing the investments (90% asset and income tests); alien trading income only without other California income.source | California taxes the net income from California sources of every corporation other than a bank for periods it is not under the franchise tax; an LLC is within it only if classified as an association.source | § 23040.1(a) leaves a corporate partner's qualifying investment-partnership income and an alien corporation's own-account securities trading income out of California-source income, which § 23501 taxes.source | Part 11 taxpayers file a return by the 15th day of the fourth month after year-end, and a return filed under the wrong chapter (franchise or income tax) is deemed filed under the proper one (§ 18601(a)).source | § 23501 taxes net income derived from California sources on or after January 1, 1937; § 23040.1(e) applies its amendments from taxable years beginning in 1999, and § 23040.1 was last amended effective January 1, 2002.source | § 23040.1 does not reach a corporation that manages the partnership's investments, is unitary with one that does, or has other California income, nor securities dealers; interests in non-investment partnerships do not qualify.source |
| CA 5/6 | Covers S corporations, meaning corporations with a valid federal S election; an LLC is covered only if classified as an association with an S election, and FTB says such LLCs file Form 100S.source | The regime is keyed to passive investment income attributable to California sources, determined under IRC § 1375; § 23811 does not itself list the income types.source | The tax applies only if the S corporation has excess net passive income for federal purposes under IRC § 1375, with subchapter C earnings and profits measured from California sources; § 23811 states no numeric threshold.source | California imposes a tax on an S corporation's passive investment income attributable to California sources, determined under IRC § 1375, at the § 23151 rate; an LLC is reached only if it is an S corporation.source | An S corporation's passive investment income bears a separate § 23811 tax at the § 23151 rate, and § 23802(e) allows a deduction for that income when computing the S corporation's Chapter 2 or 3 tax.source | S corporations file their Part 11 return by the 15th day of the third month after the close of the taxable year (§ 18601(a), (d)(1)).source | The current text of § 23811 was amended by Stats. 2003, ch. 268, effective January 1, 2004; Chapter 4.5 states no sunset or inoperative date for it.source | The tax is not imposed on an S corporation with no federal excess net passive income; California applies the IRC § 1362(d)(3) passive-income termination rule only if the federal S election is terminated.source |
| CA 6/6 | Qualified entities are taxed as partnerships or S corporations and owned only by corporations or § 17004 taxpayers; publicly traded partnerships and combined-reporting entities are excluded.source | A full-text search of Parts 10.4.1 and 10.4 found no holding-company or passive-entity carve-out from the elective tax.source | The elective tax states no holding or passive carve-out, so there is no qualifying test; a full-text search of Parts 10.4.1 and 10.4 found none.source | A qualified entity doing business in California may elect to pay an annual tax measured by its qualified net income; Part 10.4.1 covers taxable years 2026 through 2030 and Part 10.4 covered 2021 through 2025.source | The elective tax reaches an LLC only if a qualified entity elects it, and Parts 10.4.1 and 10.4 state no holding or passive carve-out.source | The election is irrevocable and made on an original, timely filed return, and the elective tax does not change any filing requirement under Parts 10, 10.2 or 11 (§§ 19910(d), 19914(d)).source | Part 10.4.1 covers taxable years 2026-2030 if IRC § 164(b)(6) was extended and stays in effect until December 1, 2031 (§ 19916); FTB's 2026 instructions say the tax is extended; Part 10.4 covered 2021-2025.source | The elective tax has no holding or passive carve-out, so no limits of one are stated; a full-text search of Parts 10.4.1 and 10.4 found none.source |
| CO 1/2 | The C-corporation regime can reach an LLC only when the LLC is taxed as a corporation for federal income-tax purposes.source | No holding- or passive-activity carve-out was located in the complete C-corporation income-tax subpart.source | The complete C-corporation income-tax subpart states no separate qualifying test for a holding or passive entity.source | Colorado imposes an annual income tax on each domestic or foreign C corporation and combined group doing business in Colorado.source | The generally applicable corporate income tax applies; no holding-entity carve-out was located in the complete C-corporation subpart.source | Every C corporation subject to the article must file a return reporting federal taxable income, Colorado modifications and credits, and required information.source | The current statutory rate provision applies to income-tax years commencing on or after January 1, 2022, subject to §39-22-627.source | No special statutory limit for holding or passive entities was located in the complete C-corporation income-tax subpart.source |
| CO 2/2 | The election is available to an S corporation or statutory partnership; an LLC is covered when it falls within the federal-return-based partnership definition.source | No holding- or passive-activity carve-out was located in the complete SALT Parity Act subpart.source | The complete SALT Parity Act subpart states no separate qualifying test for a holding or passive entity.source | An electing pass-through entity is taxed on the specified Colorado and resident-owner shares of income for a taxable period covered by its election.source | The elective tax uses the stated owner-share income base; no holding-entity carve-out from that base was located in the complete subpart.source | The S corporation or partnership makes the annual election on its §39-22-601 return, and that filed election binds all electing owners.source | The annual election applies for income-tax years beginning on or after January 1, 2018, but only while the federal §164 deduction limitation exists.source | No special statutory limit for holding or passive entities was located in the complete SALT Parity Act subpart.source |
| CT 1/3 | The chapter defines company to include corporations, joint stock companies and associations; § 12-214 reaches an unincorporated association federally taxable as a corporation.source | The net-income computation permits an all-taxpayer dividend deduction, subject to the quoted limitation for a below-20% holding in a domestic corporation.source | Deduct dividends not otherwise deducted, except 30% of dividends from a domestic corporation in which the taxpayer owns less than 20% of voting power and stock value.source | Annual corporation business tax measured by net income; an LLC is within the quoted rule only when taxable as a corporation for federal income-tax purposes.source | Dividend income receives the quoted deduction in computing net income, with a partial limitation for certain below-20% domestic-corporation holdings.source | Each company subject to the tax must render the commissioner an annual return.source | Section 12-214(a)(1) states the current net-income rate for income years beginning on or after January 1, 2000.source | The passive-investment-company exclusion is defined for a corporation related to a financial-service or insurance company and subject to the quoted operational limits.source |
| CT 2/3 | The calculation applies to each company subject to chapter 208; § 12-214 includes a federally corporate-taxed unincorporated association.source | The capital-base calculation subtracts the average value of holdings of stock of private corporations.source | The operative subtraction covers the average value of private-corporation stock holdings, including treasury stock shown on the balance sheet.source | A company subject to chapter 208 pays the larger of the § 12-214 tax and the capital-base calculation in § 12-219(a).source | Private-corporation stock holdings are subtracted from the capital-base calculation under § 12-219(a)(1)(ii).source | Each company subject to the tax must render the commissioner an annual return.source | Section 12-219(a)(1) schedules the capital-base rate by income year from pre-2024 through zero mills for income years beginning on or after January 1, 2028.source | Section 12-219a separately apportions investments other than private-corporation stock, plus cash, credits and other intangible assets.source |
| CT 3/3 | Affected business entities include partnerships and S corporations; the definitions include LLCs federally treated as partnerships or S corporations.source | No holding-activity or passive-income carve-out was located in the full text of chapter 228z.source | No operative holding-entity or passive-income carve-out test was located in chapter 228z.source | For taxable years beginning on or after January 1, 2024, an affected business entity required to file under § 12-726 may elect the tax calculated under § 12-699(c).source | No holding-entity or passive-income carve-out was located in chapter 228z; the regime is elective.source | An eligible entity must already be required to file under § 12-726 and must give written notice by its return deadline for each year it elects the tax.source | The elective regime applies for taxable years beginning on or after January 1, 2024.source | Affected business entity excludes a qualifying publicly traded partnership that agrees to file the described annual unitholder return.source |
| DC 1/2 | A District or registered foreign LLC is classified as a partnership unless federal income-tax classification requires otherwise.source | The carve-out covers an own-account activity arising solely from purchasing, holding, selling, entering, maintaining, or terminating positions in stocks, securities, or commodities.source | The activity must arise solely from the enumerated stock, security, or commodity transactions for the taxpayer's own account.source | The unincorporated-business franchise tax applies to every domestic or foreign unincorporated business for current taxable years.source | A qualifying own-account holding activity is excluded from the statutory definition of an unincorporated business, subject to the stated exceptions.source | Chapter 18 does not separately state a filing rule for an activity excluded from the unincorporated-business definition by the own-account carve-out.source | The own-account exclusion applies for tax years beginning after December 31, 2014.source | The own-account exclusion does not cover dealer inventory, ordinary-course lender debt, or non-publicly-traded REIT stock or partnership interests.source |
| DC 2/2 | An LLC classified as a corporation for federal income-tax purposes receives the same classification for District income and franchise taxation.source | The source-income rule addresses specified dividends and, for a corporation not conducting District business, specified interest receipts.source | The dividend payer must be subject to the named District tax chapter; the interest rule also requires the recipient not to conduct District business.source | The corporate franchise tax applies to every domestic or foreign corporation for current taxable years.source | Specified dividends and interest are not District-source income, while § 47-1807.02(b) separately preserves the minimum tax when business or source income is exempt.source | A corporation conducting District business or receiving District-source income must file even when that business or source income is exempt elsewhere in Chapter 18.source | The current corporate levy provision applies for taxable years beginning after December 31, 2017.source | The source-income exclusion is limited to dividends from a payer subject to the named District tax law and to interest meeting the payer and no-District-business conditions.source |
| DE 1/5 | The annual tax covers domestic LLCs, foreign LLCs registered to do business in Delaware, and registered series of domestic LLCs.source | A full-text search of the Delaware LLC Act (6 Del. C. ch. 18) found no holding-company or passive-entity carve-out from the LLC annual tax.source | The LLC Act states no holding or passive carve-out from the annual tax, so there is no qualifying test; a full-text search of chapter 18 found none.source | Every domestic LLC, every foreign LLC registered to do business in Delaware, and each registered series of a domestic LLC owes an annual tax under 6 Del. C. § 18-1107(b).source | The annual tax reaches every domestic LLC and every registered foreign LLC; the LLC Act states no exception for holding or passive LLCs.source | The Division of Corporations states LLCs file no annual report and pay the annual tax by June 1; § 18-1107(c) makes it due on June 1 after the calendar year.source | The LLC Act states no effective or sunset date for the annual tax; a full-text search of 6 Del. C. ch. 18 found none.source | The LLC Act has no holding or passive carve-out from the annual tax, so no limits of one are stated; a full-text search of chapter 18 found none.source |
| DE 2/5 | Covers domestic and foreign corporations, including associations taxable as corporations federally; an LLC is covered only if federally classified as a corporation, and a pass-through entity is not subject to it.source | § 1902(b)(8) covers in-state activity confined to managing intangible investments (stocks, bonds, notes, affiliate debt, patents, trademarks, trade names) and collecting and distributing their income.source | Exempt: corporations whose Delaware activities are confined to maintaining and managing intangible investments and collecting and distributing the income from them; the provision sets no numeric threshold.source | Delaware taxes the Delaware taxable income of every non-exempt domestic or foreign corporation; an LLC is within this tax only if it is classified as a corporation for federal income tax purposes.source | A corporation, including an LLC classified as a corporation, whose Delaware activities are confined to the § 1902(b)(8) investment activities is exempt from the corporation income tax.source | Non-exempt corporations file annual tentative and final returns; the Secretary may require exempt corporations to file information returns, and Revenue names Form CIT-HIC for § 1902(b)(8) corporations.source | Chapter 19 states the corporation income tax was first effective for income earned after December 31, 1957 (30 Del. C. § 1907).source | The exemption reaches only corporations whose in-state activities are confined to the listed activities; income from tangible property qualifies only when the property is physically located outside Delaware.source |
| DE 3/5 | Covers an entity treated as a corporation under the Internal Revenue Code that elects and is certified; an LLC is covered only if it is treated as a corporation under the Internal Revenue Code.source | Qualifying Delaware activities are investment activities (managing its intangible investments and collecting and distributing their income) and headquarters services to itself and its affiliated group.source | The entity must be treated as a corporation federally, elect with its license application, and be certified as confining its Delaware activities to investment activities and/or headquarters services.source | A certified Headquarters Management Corporation pays an annual tax in lieu of the Chapter 19 corporation income tax (30 Del. C. § 6402).source | A Headquarters Management Corporation is taxed in lieu of Chapter 19, on its own Headquarters Management Corporation taxable income base with a stated minimum tax (30 Del. C. §§ 6402-6403).source | The election is filed with the Headquarters Management Corporation license application, and annual tentative and final returns are required regardless of liability or income.source | Chapter 64 states no effective or sunset date for the Headquarters Management Corporation tax; a full-text search of the chapter found none.source | The election ends if the taxpayer revokes it or fails to limit its Delaware activities to headquarters services or investment activities.source |
| DE 4/5 | Covers a corporation that is an affiliated finance company; chapter 63 does not name LLCs, and § 18-1107(a) classifies an LLC as a corporation only if it is so classified federally.source | The qualifying activity is issuing commercial paper or other debt and using the proceeds to lend to, or buy receivables from, affiliated corporations.source | An affiliated finance company is a corporation substantially all of whose Delaware activity is issuing debt and lending the proceeds to, or buying receivables from, controlled-group affiliates.source | A corporation operating as an affiliated finance company must hold an annual license and pay a tax set by a capital-base table; an LLC is a corporation for this only if federally classified as one.source | An affiliated finance company pays a license tax measured by its capital base and, while taxed under Chapter 63, is exempt from Part III occupational license taxes (30 Del. C. § 6305).source | The license is issued for each calendar year on payment of the tax, which is due in one installment by April 30 or on commencing operations, based on certified financial statements.source | The license requirement applies to carrying on business as an affiliated finance company after May 1, 1981 (30 Del. C. § 6302).source | The treatment reaches only corporations whose Delaware activity is substantially all affiliate financing, and the § 6305 exemption is stated only for Part III occupational license taxes.source |
| DE 5/5 | Reaches "persons" as defined in § 2701 (individuals, partnerships, firms, cooperatives, corporations, associations); for a pass-through entity the Part III tax falls on the entity, not its members.source | The carve-outs reach buying debt obligations of affiliated corporations, activities solely as a partner, and corporations described in the § 1902(b)(8) intangible-investment exemption.source | § 2301(c)(3) excludes buying affiliated corporations' debt (not for affiliated finance companies); § 2301(e)(4) exempts activity solely as a partner; § 2301(o) exempts § 1902(b)(8) corporations from the (b) and (d) fees.source | Chapter 23 imposes annual license taxes on listed occupations, a general service license fee on other service businesses, and a license fee on gross receipts from licensable activities.source | § 1902(b)(8) corporations (an LLC only if corporate-classified) are exempt from the (b) and (d) fees except as commercial lessors; buying affiliated corporations' debt does not trigger the tax; acting solely as a partner is exempt.source | A full-text search of 30 Del. C. chapters 21 and 23 found no return or license-filing rule specific to an entity within the § 2301(o), (c)(3) or (e)(4) carve-outs.source | Chapters 21 and 23 state no effective or sunset date for the license and gross receipts regime or its holding carve-outs; a full-text search found none.source | The § 2301(o) exemption does not reach commercial-lessor activity (rent from Delaware commercial units); the affiliate-debt exclusion does not apply to affiliated finance companies.source |
| FL 1/1 | The Chapter 220 definition of “corporation” includes LLCs but excludes LLCs taxable as partnerships for federal income-tax purposes.source | Nonbusiness income can include rents and royalties, capital gains, interest, dividends, and patent or copyright royalties when they fall outside the taxpayer's regular business.source | The operative adjustment subtracts nonbusiness income from adjusted federal income; the definition and allocation sections determine whether an item qualifies and where it is allocated.source | Florida imposes a net-income-measured privilege tax on every taxpayer for doing business, earning or receiving Florida income, or being a Florida resident or citizen.source | Qualifying nonbusiness income is removed from adjusted federal income before apportionment and then added to Florida net income when allocated to Florida under § 220.16.source | Every taxpayer files for each year in which it is liable under Chapter 220 or must file a federal income-tax return, even if no Florida tax is due.source | No special effective or sunset period was located for the general corporate income/franchise tax or the nonbusiness-income treatment in the complete Chapter 220 search.source | The nonbusiness-income treatment excludes property income integral to regular business operations, and functionally related dividends are presumed business income; partnership-classified LLCs are outside the regime.source |
| GA 1/3 | An LLC is inside the corporate-income-tax regime only when its federal tax classification makes it a corporation; Georgia otherwise follows its federal classification.source | Georgia's corporate rules identify an affiliated-corporation dividend deduction and define the qualifying affiliate by the federal affiliated-group test.source | The deduction applies to dividends received from a U.S. affiliated corporation when the recipient is engaged in business in Georgia and is subject to Georgia income tax, to the extent the dividends were included in net income.source | Georgia imposes a corporate income tax on corporations.source | Qualifying affiliate dividends are subtracted from taxable income, reduced by expenses directly attributable to the dividend income.source | A corporation with Georgia property, business, or source income must file a Georgia income-tax return.source | No effective or sunset period for the current corporate-income-tax regime or affiliated-corporation dividend rule was stated in the searched official materials.source | The cited dividend rule defines an affiliated corporation by IRC § 1504 group membership; it does not state a general deduction for every investment holding.source |
| GA 2/3 | An LLC enters the corporate net-worth-tax regime only when treated as a corporation for income-tax purposes.source | No holding or passive activity was stated as qualifying for a corporate net-worth-tax carve-out in the searched official materials.source | No operative holding-company or passive-entity test was located for corporate net-worth tax in the searched official materials.source | Georgia's corporate net-worth tax is based on corporate net worth and is levied for the privilege of doing business or exercising a corporate franchise in Georgia.source | A corporate-classified LLC is subject to the corporate net-worth regime; domestic corporations are taxed on total net worth, with no holding/passive carve-out located.source | A new corporation files an initial net-worth return by the fifteenth day of the fourth calendar month; annual filing follows thereafter under the stated rule.source | No effective or sunset period for the current corporate net-worth-tax regime was stated in the searched official materials.source | A deficit-net-worth corporation files but owes no net-worth tax; a liquidated corporation filing its final income-tax return does not file the net-worth return.source |
| GA 3/3 | The rule covers partnerships and S corporations and treats an LLC classified as a partnership for Georgia income-tax purposes as a partnership.source | The holding-income rule addresses a partnership deriving income exclusively from buying, selling, dealing in, and holding securities for its own account and not as a broker.source | The exemption requires securities-only income for the partnership's own account, not broker activity; Rule .03(11) then directs exclusion of the exempt owner's income at entity level.source | When a qualifying partnership elects entity-level taxation, the partnership pays the income tax; this includes an LLC treated federally as a partnership.source | An electing PTE with a qualifying exempt owner excludes that owner's exempt income before apportionment and allocation; this is an owner-linked exclusion, not a blanket entity exemption.source | The entity makes the annual election on Form 600S or Form 700 by the return's due or extended due date; it becomes irrevocable after that date.source | The PTE-election regulation applies to taxable years beginning on or after January 1, 2022.source | The securities exemption does not cover the stated family-controlled entities, participating managers, or owners in a unitary business with a participating manager.source |
| HI 1/4 | Chapter 237's person definition includes corporations and every other entity, whether organized in Hawaii or another jurisdiction.source | Related-entity services and stated or imputed interest on intercompany loans, advances, or use of capital are exempt under §237-23.5(a).source | The related-entity test includes connected entities with at least 80% of total value and at least 80% of total voting power.source | Hawaii imposes general excise tax on gross income from a business or activity not otherwise taxed under chapter 237.source | Gross income includes receipts from invested business capital, including interest and royalties; specified securities-sale receipts and dividends are excluded.source | Each taxpayer files an annual return by the twentieth day of the fourth month after the taxable year closes.source | No current effective or sunset period for the general excise tax was stated in the complete chapter 237 capture.source | The gross-income definition excludes specified securities-sale and indebtedness receipts and dividends; §237-23.5 separately exempts qualifying related-entity interest.source |
| HI 2/4 | Because chapter 235 adopts the Internal Revenue Code definition of corporation, this regime reaches an LLC only when federally classified as a corporation.source | Hawaii replaces the federal corporate dividends deductions with stated deductions for specified dividend classes.source | The Hawaii deduction includes 70% of dividends from another corporation when the federal §243 condition is otherwise met, plus three full-deduction classes.source | Hawaii imposes tax on the taxable income of every corporation, including a corporation carrying on business in partnership.source | Corporate dividend income receives Hawaii-specific deduction treatment: full deductions for three stated classes and a 70% deduction for qualifying other-corporation dividends.source | Every corporation with gross income subject to chapter 235 files a return; an affiliated domestic group may file a consolidated return under the stated conditions.source | No current effective or sunset period for the corporate levy or dividend modification was stated in the complete chapter 235 capture.source | The dividend rules remove the stated deductible portions from Hawaii taxable income; they do not state a general exemption for a holding LLC.source |
| HI 3/4 | Part VII defines an S corporation by a valid federal §1362(a) election; an LLC enters this regime only through corporate classification and that election.source | The entity-level exception is triggered by S-corporation income subject to federal income tax and attributable to Hawaii, not by a separate state holding-activity category.source | The statutory test is whether S-corporation income is subject to federal income tax, modified under §235-123, and attributable to Hawaii.source | An S corporation is generally outside §235-71, but federally taxed S-corporation income attributable to Hawaii is taxed at the highest corporate marginal rate.source | Federally taxed S-corporation income attributable to Hawaii is taxed at the highest marginal corporate rate and then reduces state-attributable S-corporation income.source | An S corporation files an annual Hawaii return when its Hawaii activities would require a C corporation return under §235-92.source | No current effective or sunset period for the Part VII entity-level exception was stated in the complete chapter 235 capture.source | Outside the stated federally taxed-income exception, an S corporation is not subject to the corporation tax imposed by §235-71.source |
| HI 4/4 | The member definition expressly includes an LLC treated federally as a partnership or S corporation; the partnership definition also includes a partnership-classified LLC.source | A complete chapter 235 search found no holding-company or passive-activity carve-out from the elective PTE tax.source | Section 235-51.5 states no holding or passive carve-out and therefore no holding-activity qualifying test; the complete chapter search found none.source | An electing partnership or S corporation pays entity-level tax on qualified members' Hawaii taxable distributive shares and guaranteed payments.source | The elective base uses all qualified members' Hawaii taxable distributive shares and guaranteed payments; no holding or passive carve-out was located.source | A separate election is filed each tax year in the prescribed form, signed by all current members or an authorized officer, manager, or member; it is irrevocable for that year.source | The elective pass-through entity tax applies to taxable years beginning after December 31, 2022.source | The statutory definitions exclude publicly traded partnerships and limit qualified members to individuals, trusts, and estates.source |
| IA 1/2 | For this subchapter, corporation includes an LLC taxed as a corporation under the Internal Revenue Code.source | The statutory carve-out names a foreign holding or parent company whose Iowa activity is owning and controlling an Iowa subsidiary.source | The carve-out requires a foreign corporation, the stated subsidiary ownership/control activity, and no Iowa physical presence related to that ownership or control.source | Iowa imposes corporate income tax on each corporation doing business in Iowa or deriving income from Iowa sources.source | A qualifying foreign holding or parent corporation is not considered doing business in Iowa or deriving Iowa-source income solely by the stated subsidiary ownership/control activity.source | The corporate return rule requires a corporation to file a return signed by its president or another authorized officer; no separate holding-company return rule is stated.source | The Department identifies the current corporate-rate schedule as effective for tax years beginning on or after January 1, 2024.source | The holding carve-out is limited to a foreign corporation with no related Iowa physical presence; it does not state an exclusion for a domestic Iowa holding LLC or a foreign holder with such presence.source |
| IA 2/2 | Department guidance includes qualifying LLCs taxed as partnerships or S corporations among entities eligible to elect PTET.source | No holding- or passive-activity carve-out was located in complete § 422.16C or the complete Department PTET guidance.source | The PTET statute and guidance state no separate qualifying test for a holding or passive entity.source | An electing taxpayer pays entity-level tax on its properly determined Iowa taxable income, allocated and apportioned under Department rules.source | An eligible LLC may elect the entity-level tax on its Iowa taxable income; no holding-entity carve-out from that elective base was located.source | A separate irrevocable election is made for each tax year, and the entity-level tax is due with the taxpayer's return.source | The election is available for qualifying tax years beginning on or after January 1, 2022 and is no longer scheduled to expire.source | A publicly traded partnership and a single-member or other federally disregarded LLC cannot make their own PTET election.source |
| ID 1/4 | An entity classified or taxed federally as a corporation is treated as a corporation for Idaho income-tax purposes.source | No holding-activity carve-out is stated; Tax Commission guidance instead lists an inactive or name-holder corporation among corporations that must file.source | No operative holding-entity carve-out test is stated for this corporate regime.source | Idaho imposes the tax on corporate income on the corporate branch described in Idaho Code § 63-3025.source | Tax Commission guidance lists an inactive or name-holder corporation among corporations that must file; it states no holding-only carve-out.source | The corporate Idaho return is due on the fifteenth day of the fourth month after the tax year closes.source | The cited operative period for the tax on corporate income begins on 2025-01-01.source | The stated interest/dividend allocation reaches Idaho-commercial-domicile income unless it is apportionable; the rule does not state a general holding-entity exemption.source |
| ID 2/4 | An entity classified or taxed federally as a corporation is treated as a corporation for Idaho income-tax purposes.source | No holding-activity carve-out is stated; Tax Commission guidance instead lists an inactive or name-holder corporation among corporations that must file.source | No operative holding-entity carve-out test is stated for this corporate regime.source | Idaho imposes the franchise tax on the corporate branch described in Idaho Code § 63-3025A.source | Tax Commission guidance lists an inactive or name-holder corporation among corporations that must file; it states no holding-only carve-out.source | The corporate Idaho return is due on the fifteenth day of the fourth month after the tax year closes.source | The cited operative period for the franchise tax begins on 2001-01-01.source | The stated interest/dividend allocation reaches Idaho-commercial-domicile income unless it is apportionable; the rule does not state a general holding-entity exemption.source |
| ID 3/4 | Section 63-3026B expressly includes an LLC federally treated as a partnership or S corporation, subject to the election and exempt-entity limit.source | No holding or passive-activity carve-out is stated in the complete affected-business-entity tax section.source | No operative holding-entity carve-out test is stated in the complete affected-business-entity tax section.source | An electing partnership or S corporation transacting business in Idaho pays entity-level tax on its Idaho-source affected-business-entity income.source | The complete ABE-tax section states no holding or passive-entity exemption or different treatment.source | An ABE pays by the fifteenth day of the fourth month after the taxable year closes; a separate election is required each year.source | A partnership or S corporation may make a separate ABE election for any taxable year.source | The stated interest/dividend allocation reaches Idaho-commercial-domicile income unless apportionable; §63-3026B separately excludes an exempt member's apportioned share.source |
| ID 4/4 | The additional tax reaches every income-return filer and also a PTE for each individual included on its composite return.source | Unknown Verified absenceThe checked official source does not state this value.source | The only test is in § 63-3083: all the entity's income or loss is reportable by another taxpayer and it has no Idaho taxable income; it is not a holding-activity test.source | Every person required to file an Idaho income-tax return pays the additional excise tax imposed by §63-3082.source | An LLC is excluded by statute from Idaho's $10 permanent building fund tax only if all its income or loss is reportable by another taxpayer and it has no Idaho taxable income (§ 63-3083); otherwise it pays as a filer (§ 63-3082(1)).source | The additional tax is tied to the obligation to file an income-tax return and is paid by the return filer.source | Section 63-3082 states the additional tax for every person required to file an income-tax return and supplies no sunset in the operative text.source | Idaho's permanent building fund tax does not reach an entity whose income or loss is all reportable by another taxpayer and that has no Idaho taxable income (§ 63-3083).source |
| IL 1/3 | An entity, expressly including an Illinois LLC, is treated as a corporation when it has that federal income-tax classification.source | The holding-company definition covers controlling interests and substantially all income from stated dividends, interest, rents, royalties, charges, gains, and related property.source | The complete test defines the holding company, states the multiple-group allocation, and permits a petition for single-group treatment when the default is not a fair reflection.source | Illinois imposes a net-income tax on corporations; the current corporate rate provision applies to taxable years beginning on or after July 1, 2017.source | A qualifying holding company's base income and apportionment factors are assigned among its unitary groups under the stated pro rata or consistently applied reasonable method.source | A liable person must file a return; since 1993, non-S corporate members of the same unitary group are treated as one taxpayer for the stated return and liability purposes.source | The stated current corporate rate applies to taxable years beginning on or after July 1, 2017.source | The special holding-company treatment excludes the stated bank holding-company route and does not extend beyond corporations meeting the ownership, income, expense, and group conditions.source |
| IL 2/3 | The tax covers every corporation, including S corporations, partnership, and trust; the definitions expressly bridge corporation- and partnership-classified LLCs.source | For a corporate-classified LLC, the holding-company definition covers controlling interests and the stated holding receipts, gains, property, services, and expenses.source | The complete corporate holding-company test states the allocation and permits a petition for single-group treatment when the default is not a fair reflection.source | Illinois imposes the Personal Property Tax Replacement Income Tax, measured by net income, on every stated corporation, partnership, and trust.source | A corporate-classified LLC meeting the holding-company and unitary-group conditions has base income and factors assigned under the special rules; other covered types retain the general regime.source | A person liable for tax under the Act must file; non-S corporate members of one unitary group are treated as one taxpayer for the stated return and liability purposes.source | The replacement tax begins July 1, 1979 for taxable years ending after June 30, 1979; subsection (d) states the later rate periods.source | The special holding-company allocation excludes the stated bank route and is a corporation rule; partnership- or S-corporation-classified LLCs remain only within the general replacement-tax terms.source |
| IL 3/3 | The election is for a non-publicly-traded partnership or S corporation; Illinois expressly includes a federally partnership-classified LLC and defines the S-corporation route.source | The tiered-partnership rule addresses an electing taxpayer that is a partner of another electing taxpayer, including lower-tier distributive net income.source | The holding entity must itself elect under paragraph (1) and be a partner of another electing taxpayer; the subtraction includes income passed through electing partnership tiers.source | Within the stated taxable-year window, an electing partnership or S corporation is subject to Illinois PTE tax at the entity level.source | An electing partnership that owns an interest in another electing partnership subtracts its distributive share of the lower-tier electing partnership's net income.source | A separate prescribed election is required for each taxable year and is irrevocable once made; the Act's general return rule applies to a person liable for the tax.source | The election is limited to years ending on or after December 31, 2021 and beginning before January 1, 2026, and only while the stated federal deduction limit applies.source | The election excludes publicly traded partnerships and years beginning in 2026 or later; the tiered subtraction requires an interest in another electing partnership.source |
| IN 1/2 | The statutory corporation definition includes corporations, associations, REITs, business trusts, and federally corporation-classified publicly traded partnerships.source | A corporation receives a deduction for dividends from a foreign corporation; the deduction percentage varies with voting-power ownership.source | The foreign-source-dividend deduction states three ownership bands and the corresponding deduction percentages, plus the included and excluded dividend categories.source | Indiana imposes corporate adjusted gross income tax on every corporation's adjusted gross income derived from Indiana; an LLC taxed federally as an association falls in that classification.source | A corporation-classified LLC remains within corporate adjusted gross income tax, while qualifying foreign-source dividends receive the ownership-tiered statutory deduction.source | Every corporation with Indiana-source gross income files a return; the statute states the applicable fourth- or fifth-month due-date rule.source | The current corporate adjusted gross income tax rate applies after June 30, 2021.source | The deduction is confined by definition to dividends from a foreign corporation.source |
| IN 2/2 | An electing entity is a listed pass-through entity subject to Subchapter K or S; the incorporated pass-through definition expressly includes limited liability companies.source | The investment-partnership provisions cover the enumerated securities, bank deposits, interest, dividends, gains, derivatives, commodities, and qualifying partnership interests.source | The rule requires federal partnership status, both 90% tests, nondealer status, qualifying investment-partnership income, and distribution to a nonresident partner.source | A Subchapter K or S pass-through entity may elect Indiana adjusted gross income tax at entity level; the tax is imposed on aggregate direct-owner shares.source | For PTET's nonresident-owner base, qualifying investment-partnership income is allocated to the partner's residence or commercial domicile unless an operational exception applies.source | The electing entity attaches a schedule calculating tax and each direct owner's credit and remits the tax with its return, subject to credited payments.source | The PTET chapter applies after 2021; the investment-partnership allocation rule applies to taxable years beginning after December 31, 2025.source | The special allocation excludes the stated security-interest income and yields to business-income treatment for integrally related, operational, or working-capital investment activity.source |
| KS 1/2 | Kansas Department of Revenue states that LLC business income may be taxed as a corporation or partnership.source | The corporate base subtracts 80% of qualifying dividends from corporations incorporated outside the United States or the District of Columbia.source | The subtraction is 80% of qualifying foreign-corporation dividends included in federal taxable income, subject to the stated post-2020 limits.source | Kansas imposes corporate income tax on every corporation doing business in Kansas or deriving income from Kansas sources.source | Qualifying foreign-corporation dividends receive an 80% subtraction from federal taxable income in computing Kansas corporate taxable income.source | A corporation doing business in Kansas or deriving Kansas-source income files a Kansas corporate return when it is required to file a federal income-tax return, whether or not tax is due.source | For taxable years beginning after December 31, 2020, the foreign-dividend subtraction does not apply to the two categories stated in K.S.A. 79-32,138(c)(v).source | The Kansas-specific subtraction is limited to 80% of dividends from corporations incorporated outside the United States or the District of Columbia and excludes the stated post-2020 amounts.source |
| KS 2/2 | The election is available to an S corporation or partnership; Department guidance states that an S-corporation-treated single-member LLC may elect.source | Department guidance states that a partnership or S corporation with only portfolio income, including interest, dividends, and securities capital gains, may make the election.source | No holding- or passive-entity qualifying test was located in the complete SALT Parity Act search.source | An electing pass-through entity is subject to Kansas entity-level tax computed under K.S.A. 79-32,287(a).source | The SALT Parity Act states no separate holding- or passive-entity treatment.source | The S corporation or partnership makes the election on its filed return, and that filing binds all electing pass-through entity owners.source | The entity-level tax provisions apply to taxable years commencing on or after January 1, 2022.source | For a partnership, the statutory definition of electing pass-through entity owner excludes a C corporation partner.source |
| KY 1/3 | For current years, Kentucky follows an LLC's federal income-tax classification; a corporation-classified LLC falls under the corporate imposition rule.source | For corporation-tax calculations, Kentucky expressly excludes all dividend income from gross income.source | The operative corporate-income rule is categorical: exclude all dividend income; it states no percentage threshold.source | An LLC is subject to Kentucky corporation income tax when its federal tax treatment is corporate; KRS 141.040 imposes the tax on every nonexempt corporation doing business in Kentucky.source | A corporation-classified holding LLC remains within corporation income tax, but all dividend income is excluded from the Kentucky gross-income calculation.source | Income returns are due April 15 for calendar-year taxpayers or the fifteenth day of the fourth month after a fiscal year closes.source | The current corporate gross- and net-income calculation in KRS 141.039 is effective July 15, 2026.source | The dividend exclusion is limited to dividend income; the same calculation expressly includes interest from sister-state obligations.source |
| KY 2/3 | LLET reaches both corporations and limited-liability pass-through entities; the pass-through definition expressly includes LLCs not taxed federally at entity level.source | The LLET carve-out reaches a pass-through entity holding only investments that produce income not taxable to a nonresident individual if held directly.source | A qualified investment partnership must be a pass-through entity that, throughout the taxable year, holds only investments producing the specified nonresident-exempt income.source | Kentucky imposes annual LLET on every corporation and limited liability pass-through entity doing business in Kentucky, subject to stated exceptions.source | A holding LLC that meets the qualified-investment-partnership test is expressly not subject to LLET under KRS 141.206(14)(b).source | A qualified investment partnership remains subject to the other PTE provisions, including the annual federal-return-copy filing rule in KRS 141.206(1).source | The current qualified-investment-partnership provision in KRS 141.206 is effective July 15, 2026.source | The exemption is limited to a pass-through entity holding only investments that produce income nontaxable to a nonresident individual if held directly; the entity remains subject to other PTE provisions.source |
| KY 3/3 | The statutory pass-through-entity definition includes LLCs not taxed federally at entity level; Revenue guidance also confirms disregarded SMLLCs may elect.source | Unknown Checked — record silentThe official record does not state thissource | Unknown Checked — record silentThe official record does not state thissource | An authorized person may elect annually to have the KRS 141.020 tax imposed on a pass-through entity, based on ordinary and separately stated income calculated under KRS 141.206.source | Unknown Checked — record silentThe official record does not state thissource | The election uses a department-prescribed form and, for current years, must be made by the fourth-month deadline or the tenth-month extended-return deadline.source | The election applies to taxable years beginning on or after January 1, 2022; KRS 141.209 became effective March 31, 2023.source | Unknown Checked — record silentThe official record does not state thissource |
| LA 1/2 | The regime reaches corporations and other entities taxed as corporations for federal income-tax purposes; the provision excludes insurance companies as provided by the statute.source | The statute provides deductions for dividends and interest that otherwise would be included in gross income.source | The dividend and interest deductions apply to amounts otherwise included in gross income; the interest provision permits a tax election for interest from a corporation controlled through at least fifty percent voting-stock ownership.source | Louisiana imposes tax on the Louisiana taxable income of corporations and other entities taxed as corporations for federal income-tax purposes, excluding the specified insurance companies.source | Dividends and interest otherwise included in gross income receive statutory deductions, subject to the controlled-corporation interest election stated in the provision.source | Every corporation subject to the tax must file a return stating gross-income items and allowed deductions and credits.source | The current rate provision applies to taxable years beginning on or after January 1, 2025.source | The stated holding-income deductions address dividends and interest; the interest provision separately addresses the controlled-corporation election.source |
| LA 2/2 | The election is available to an S corporation or an entity taxed as a partnership for federal income-tax purposes.source | The corporation-income-tax Part supplies deductions for dividends and interest, and the election section applies that Part to electing entities unless otherwise provided.source | The incorporated Part provides dividend and interest deductions; the interest provision includes the stated fifty-percent voting-stock threshold for the controlled-corporation election.source | Louisiana taxes the Louisiana taxable income of an entity making the pass-through election at the rate referenced for individuals.source | The election section applies the corporation-income-tax Part to electing entities, and that Part provides deductions for dividends and interest otherwise included in gross income.source | The election must be made in writing within the statutory period, subject to the secretary's reasonable-cause authority for a late election.source | The election applies for the elected taxable year and all succeeding taxable years until termination under the statute.source | An entity filing a composite partnership return under La. R.S. 47:201.1 cannot make the election for the same tax year.source |
| MA 1/3 | “Business corporation” includes corporations and other entities, including an LLC, when classified as a corporation for federal income-tax purposes.source | The separate security-corporation treatment covers exclusive proprietary securities activity and defines eligible securities to include listed instruments, cash equivalents, specified fund interests, and passive vehicles.source | A business corporation must act exclusively on its own behalf in the stated securities activities, not as a broker, satisfy the exclusions, apply before year-end, and be classified by the commissioner.source | Section 39 imposes the corporate excise on every covered business corporation for stated charter, business, and property incidents in Massachusetts.source | A corporation taxable under the security-corporation provision is not subject to the general § 39 excise and instead pays the § 38B gross-income-measured excise.source | Every Chapter 63 business corporation files the return required by Chapter 62C § 11, subject to its S-corporation, other-corporation, and combined-report timing rules.source | Section 39 states the current income-measure period as tax years beginning on or after January 1, 2012.source | The general § 39 excise does not reach a corporation that is taxable under the separate § 38B security-corporation excise.source |
| MA 2/3 | The regime covers a financial institution or business corporation; Chapter 63 defines a business corporation to include another entity federally classified as a corporation.source | Eligible securities include public-market instruments, cash equivalents, specified REIT/RIC/REMIC interests, guaranteed mortgage-backed securities, certain CMOs, and approved passive vehicles.source | Eligibility requires exclusive proprietary securities activity, no brokerage activity, the stated exclusions, a timely classification application, and commissioner classification that remains unrevoked.source | Section 38B imposes a gross-income-measured excise on a qualifying financial institution or business corporation classified as a security corporation.source | A qualifying security corporation is outside the general § 39 excise and pays the separate gross-income-measured § 38B excise.source | The corporation applies to the commissioner for security-corporation classification before the taxable year ends; the general Chapter 62C corporate-return rule also applies.source | No special commencement or sunset period was located for the § 38B security-corporation classification or excise in the complete Chapter 63 search.source | An ownership interest in a related-member REIT is not a security for § 38B; subsection (a) also excludes brokerage activity, DISC securities, and bank holding companies from its stated class.source |
| MA 3/3 | An eligible pass-through entity includes an S corporation, partnership, or LLC treated as an S corporation or partnership under the cited federal provisions.source | No holding- or passive-activity carve-out was located in the complete five-section Chapter 63D.source | No operative holding- or passive-entity carve-out test was located in Chapter 63D.source | An eligible pass-through entity may elect the Chapter 63D excise on qualified income taxable in Massachusetts.source | Chapter 63D states the elective qualified-income rule but no distinct treatment for a holding or passive eligible pass-through entity.source | The electing entity pays on its original timely filed return, due when its partnership information return or corporate excise return would be due under Chapter 62C.source | Chapter 63D applies for tax years beginning on or after January 1, 2021, but not for a year when the cited federal state-and-local-tax deduction limit has expired or is not in effect.source | Qualified income is limited to amounts allocable to qualified members, defined as natural persons, trusts, or estates subject to Chapter 62; other owners are outside that defined base.source |
| MD 1/2 | An LLC classified under federal Subchapter C or S files the appropriate corporate return; an S corporation has the narrower base stated in § 10-304(3).source | The corporate subtraction includes qualifying dividends from a foreign corporation in which the recipient owns at least 50% of outstanding capital stock.source | The dividend must be included in federal taxable income; the recipient must own at least 50% of the payer, and the payer must be organized under foreign law.source | Maryland imposes income tax on the Maryland taxable income of each corporation, subject to the statutory exclusions.source | Qualifying foreign-corporation dividends are subtracted from federal taxable income when determining Maryland modified income.source | An LLC classified under federal Subchapter C or S files the appropriate corporate return; a disregarded single-member LLC reports through its member.source | The current corporate levy and dividend-subtraction provisions do not state an effective or sunset period in the codified sections.source | The subtraction is limited to included dividends, at least 50% direct or indirect ownership, and a payer organized under foreign law.source |
| MD 2/2 | The pass-through entity definition expressly includes an LLC that is not taxed as a corporation under Title 10.source | No holding-activity carve-out was located; the quoted limitation concerns a member that is itself a Maryland-formed or registered PTE.source | The located exception is limited to the non-elective tax on a member that is itself a Maryland-formed or registered PTE; it is not a holding-activity test.source | Each pass-through entity must pay the tax for nonresident-member shares or may elect to pay it for all member shares.source | The statute imposes the tax on each pass-through entity and expressly includes an LLC not taxed as a corporation; no holding-activity carve-out was located.source | A partnership-classified LLC files a partnership return, while a disregarded single-member LLC reports profit or loss through its member; electronic filing begins after 2026.source | The current PTE levy provision does not state an effective or sunset period; § 10-819.1 separately dates the future electronic-filing rule.source | The non-elective tax excludes specified shares of Maryland PTE, REIT, and Internal Revenue Code § 501 members.source |
| ME 1/1 | Maine follows an LLC's federal tax classification; a corporate-classified LLC is within the taxable-corporation definition when it has Maine nexus and realizes Maine net income.source | The statute exempts qualifying corporate small-business investment companies and separately subtracts 50% of specified affiliated-corporation dividend income.source | Exemption requires federal SBIC licensing, Maine commercial domicile and business primarily in Maine; the dividend subtraction is 50% and applies to the quoted affiliated income.source | For tax years beginning on or after January 1, 2018, § 5200 imposes tax on each taxable corporation and each qualifying unitary group.source | A corporate SBIC meeting § 5202-A is exempt under Part 8; § 5200-A separately subtracts 50% of specified affiliated-corporation dividend income.source | Every taxable corporation required to file a federal income-tax return files a Maine return; a unitary affiliate also files the statutory combined report.source | The current rate schedule applies to tax years beginning on or after January 1, 2018.source | The dividend subtraction excludes subpart F, § 951A and § 965 income; § 5200-B also preserves federal Public Law 86-272 protection.source |
| MI 1/2 | An LLC enters the corporate-income-tax regime when it is required or elects to file as a C corporation; insurance companies and financial institutions are excluded from this definition.source | The corporate base deducts qualifying foreign dividends and royalties and interest from United States obligations, subject to the statutory source and inclusion conditions.source | The deductions require federal-taxable-income inclusion and the stated foreign-payor or U.S.-obligation source tests.source | Michigan levies corporate income tax on every taxpayer with Michigan business activity or an interest in a Michigan-active flow-through entity, subject to federal limits.source | A corporate-classified holding LLC receives different base treatment for the specified foreign dividends/royalties and U.S.-obligation interest.source | The annual or final corporate-income-tax return is due by the last day of the fourth month after the tax year ends.source | The Corporate Income Tax part was added by 2011 PA 38, effective January 1, 2012.source | The quoted deductions are bounded by their stated sources: specified non-U.S. payors/foreign operating entities and United States obligations.source |
| MI 2/2 | The elective regime covers S corporations and partnerships, including an LLC treated federally as a partnership; disregarded, corporate-treated and publicly traded entities are excluded.source | The FTE base deducts business income received as a member of another flow-through entity to the extent it increased federal taxable income.source | The inter-FTE deduction is limited by separate rules for a positive-income electing lower-tier FTE, whose subsection (2) adjustments are excluded, and a non-electing lower-tier FTE, whose positive income is added back.source | Subject to MCL 206.847, Michigan levies Flow-Through Entity Tax on every electing taxpayer with Michigan business activity.source | The inter-FTE base follows three linked rules: deduction, exclusion of an electing positive-income lower-tier FTE's subsection (2) adjustments, and addback for a non-electing lower-tier FTE.source | An annual or final FTE return is due by the last day of the third month after the taxpayer's tax year ends.source | The election begins with tax years starting in 2021, and the tax is imposed only while IRC § 164(b)(6)(B) limits the corresponding individual state-and-local-tax deduction.source | The deduction excludes an electing positive-income lower-tier FTE's subsection (2) adjustments, while a non-electing lower-tier FTE's positive-business-income share is added back.source |
| MN 1/6 | Minnesota follows an LLC's federal income-tax classification, so the franchise regime reaches an LLC federally treated as a corporation.source | The corporate dividend deduction addresses stock holdings and dividend income but excludes a business consisting principally of holding stocks and collecting the resulting income and gains.source | The deduction is 50% at 20%-or-more ownership and 40% below 20%, subject to statutory asset and holding-business limits.source | Minnesota imposes an annual franchise tax on a corporation whose state contacts produce Minnesota-source gross income.source | Qualifying corporate dividends receive a 50% or 40% deduction, but the deduction is denied when the business principally holds stocks and collects the related income and gains.source | A corporation within Minnesota's jurisdiction to tax must file a return.source | No current sunset or effective period for the franchise-tax regime was stated in the complete chapter 290 capture.source | The dividend deduction does not reach dividends from a federally exempt corporation or a REIT and is subject to the holding-business exclusion.source |
| MN 2/6 | Federal classification controls LLC treatment; §290.0922 reaches filing C corporations, S corporations, and partnerships.source | The minimum-fee exemptions include REITs, regulated investment companies, and entities with a valid federal §860D(b) election.source | Qualifying REITs, regulated investment companies or their funds, and §860D(b)-electing entities are among the expressly exempt classes.source | Minnesota imposes the minimum fee on filing S corporations and partnerships, with a separate included fee for filing C corporations.source | Specified investment-entity classes are exempt, and intangible property is excluded from the Minnesota-property factor; other filing entities remain subject under the statutory factors.source | For an S corporation or partnership, the minimum fee is due on or before the return due date stated in §290.0922, subd. 1(b).source | No current sunset or effective period for the minimum fee was stated in the complete chapter 290 capture.source | The fee does not reach the expressly exempt entities, including REITs, regulated investment companies or their funds, and §860D(b)-electing entities.source |
| MN 3/6 | A qualifying entity expressly includes an LLC taxed as a partnership or S corporation when it has at least one qualifying owner.source | Complete chapters 289A and 290 state no holding-company or passive-activity carve-out from the elective PTE tax.source | No holding or passive qualifying test is stated for the elective PTE tax; the complete two-chapter search found none.source | Minnesota imposes pass-through entity tax on a qualifying entity that makes the annual election, measured by qualifying owners' tax liabilities.source | The elective tax uses the sum of each qualifying owner's tax liability; no holding-company or passive-income carve-out was located.source | The election is made by the return due date, requires owners holding more than 50% of qualifying-owner interests, binds all qualifying owners, and is irrevocable for the year.source | The election applies to taxable years beginning after 2020 and expires with federal IRC §164(b)(6)(B), without ending later audit authority.source | A publicly traded partnership is not a qualifying entity, and the election must exclude owners who are not qualifying owners.source |
| MN 4/6 | The regime reaches an LLC only through federal corporate classification and a valid federal S election.source | The qualifying event is recognized built-in gain as defined by federal §1374 after the stated S-election timing.source | The statute requires a post-1986 federal S election and recognized built-in gain under federal §1374.source | Minnesota taxes recognized built-in gain of an S corporation with a post-1986 S election at the corporate rate.source | The qualifying built-in gain is taxed at the corporate rate notwithstanding the general S-corporation exemption in §290.9725.source | An S corporation files a return for each taxable year in which its federal S election is in effect.source | The stated S-election condition is an election after December 31, 1986.source | The subdivision does not apply when the corporation had an S election in effect for every taxable year; predecessor status is combined.source |
| MN 5/6 | The regime reaches an LLC only through federal corporate classification and a valid federal S election.source | The qualifying receipt is net capital gain exceeding the statutory dollar and percentage thresholds.source | The legacy test combines a pre-1987 S election, net capital gain over $25,000 and 50% of federal taxable income, and federal taxable income over $25,000.source | Minnesota imposes an entity tax on a legacy S corporation meeting the pre-1987 election and capital-gain thresholds.source | A qualifying legacy S corporation pays entity-level tax at the corporate rate on the lesser statutory capital-gain income base.source | An S corporation files a return for each taxable year in which its federal S election is in effect.source | Eligibility is limited to an S corporation whose federal S election was made before January 1, 1987, subject to the stated lookback exclusions.source | The tax does not apply after three immediately preceding S-election years or to a corporation under four years old with an S election for every year of existence.source |
| MN 6/6 | The regime reaches an LLC only through federal corporate classification and a valid federal S election.source | The regime expressly addresses passive investment income and accumulated C-corporation earnings and profits.source | The S corporation must have C-corporation earnings and profits at year-end and passive investment income over 25% of gross receipts.source | Minnesota taxes an S corporation with accumulated C-corporation earnings and profits when passive investment income exceeds 25% of gross receipts.source | A qualifying S corporation pays entity-level tax at the corporate rate on the lesser statutory excess-net-passive-income base.source | An S corporation files a return for each taxable year in which its federal S election is in effect.source | No current sunset or effective period for the S-corporation passive-investment-income tax was stated in the complete chapter 290 capture.source | The Minnesota tax is waived when the taxpayer receives the corresponding federal §1375(d) waiver.source |
| MO 1/2 | Chapter 143 defines corporation to include associations and imports comparable federal income-tax meanings; the LLC route is limited to federal corporate classification.source | The corporate base subtracts stated Missouri-source corporate dividends and separately allocates intangible gains, interest, dividends, and patent or copyright royalties.source | Dividend subtraction requires inclusion in federal taxable income and Missouri source; other holding receipts follow the stated domicile or utilization allocation tests.source | For tax years beginning in 2020 or later, Missouri imposes corporation income tax on Missouri taxable income at the rate stated in § 143.071.3.source | A corporate-classified holding LLC remains within the regime, while corporate dividends and other holding receipts receive the stated subtraction and source-allocation treatment.source | A nonexempt corporation files when it must file federally and has the stated Missouri-source gross income; the return is due on the stated fourth-month date.source | The current corporation-income provision applies to tax years beginning on or after January 1, 2020.source | An S corporation is not subject to § 143.071 or other corporation income-tax sections; an S-corporation-classified LLC instead enters the elective ABE route if eligible and elected.source |
| MO 2/2 | An ABE is an electing partnership or S corporation; both definitions expressly include an LLC with the corresponding federal income-tax classification.source | The ABE base incorporates § 143.455 holding-receipt sourcing and adjusts for a holding ABE's distributive share of another ABE's Missouri net income or loss.source | The nested-entity adjustment requires the holding ABE to be a direct or indirect member of another ABE; other holding receipts follow § 143.455 source tests.source | Missouri imposes the SALT Parity Act tax on each electing affected partnership or S corporation doing business in the state.source | The ABE base uses holding-receipt source allocation and removes another ABE's distributive Missouri net income, or adds its distributive Missouri net loss.source | An ABE files an affected-business-entity tax return for each subject year, and a separate prescribed election is required for every tax year.source | The affected-business-entity tax applies only to tax years ending on or after December 31, 2022.source | The nested-entity adjustment is limited to an interest in another electing ABE; publicly traded partnerships and non-partnership/non-S classifications are outside that stated route.source |
| MS 1/3 | A domestic or foreign LLC classified federally as a corporation files as a corporation for Mississippi income-tax purposes.source | DOR guidance addresses nonbusiness income and wholly passive investment income from outside Mississippi as an allocation claim.source | The allocation claim requires a statement of reasons; wholly passive out-of-state investment income also requires a detailed explanation.source | Mississippi imposes income tax on corporate net income; an LLC reaches this filing branch when classified federally as a corporation.source | DOR treats the identified passive out-of-state investment income through a separate allocation and documentation procedure, not as an entity exemption.source | A corporation must file a corporate income and franchise tax return even when inactive; DOR places a federally corporate LLC in this branch.source | The cited imposition applies to the listed calendar and fiscal years and ‘all taxable years thereafter.’source | The stated allocation procedure is limited to nonbusiness income and wholly passive investment income from outside Mississippi and requires supporting explanation.source |
| MS 2/3 | A domestic or foreign LLC classified federally as a corporation files as a corporation for Mississippi franchise-tax purposes.source | A holding corporation must own at least 80% of another corporation's stock value and voting power and derive at least 95% of gross receipts from the listed sources.source | The test combines 80% stock-value ownership, 80% voting-power ownership, and 95% of gross receipts from the listed sources.source | Mississippi imposes a franchise or excise tax on domestic and foreign corporations and partnerships treated as corporations.source | A qualifying holding corporation computes an exclusion from capital for the stated portion of its investment in subsidiary stock or securities.source | The corporate income and franchise tax return is due on the fifteenth day of the fourth month after the taxable year closes.source | The corporation franchise tax law is repealed from and after January 1, 2028.source | The holding-company exclusion is limited to the calculated portion of capital attributable to stock or securities of a subsidiary corporation.source |
| MS 3/3 | DOR places a federally partnership-classified LLC in the PTE filing branch; §27-7-26 permits a similar pass-through entity to elect.source | Unknown Checked — record silentThe official record does not state thissource | Unknown Checked — record silentThe official record does not state thissource | A partnership, S corporation, or similar pass-through entity may elect to pay Mississippi income tax at the entity level.source | Unknown Checked — record silentThe official record does not state thissource | An electing PTE files Form 84-105, checks the electing-PTE box, and attaches Form 84-381.source | The elective entity-level regime applies for calendar year 2022 and each calendar year thereafter.source | Unknown Checked — record silentThe official record does not state thissource |
| MT 1/3 | Montana's corporation definition expressly includes an LLC treated as an association for federal income-tax purposes and not treated as a disregarded entity.source | The regulated-investment-company provision changes the corporate base through a dividends-paid deduction subject to the stated income and dividend limits.source | The operative rule requires a regulated investment company or fund under the cited federal definition and states every Montana deduction condition and limitation.source | A federally corporation-classified LLC is a corporation under Montana law and pays corporate income tax annually when engaged in business in Montana.source | A qualifying regulated investment company remains within the corporate regime but receives the stated dividends-paid deduction with express exclusions.source | A corporation files an accurate net-income return for each tax period under the stated calendar- or fiscal-year due-date rule.source | The corporate income tax provision states that a corporation engaged in Montana business pays the tax annually.source | The RIC deduction excludes dividends attributable to income not taxed when earned and disallows a dividends-received deduction; the NOL deduction is also unavailable.source |
| MT 2/3 | Montana's corporation definition expressly includes an LLC treated as an association for federal income-tax purposes and not treated as a disregarded entity.source | The regulated-investment-company provision changes the corporate base through a dividends-paid deduction subject to the stated income and dividend limits.source | The operative rule requires a regulated investment company or fund under the cited federal definition and states every Montana deduction condition and limitation.source | The alternative corporate income tax reaches every corporation outside part 1 that is taxable under an income tax and has Montana-source net income.source | A qualifying regulated investment company remains within the corporate regime but receives the stated dividends-paid deduction with express exclusions.source | A corporation files an accurate net-income return for each tax period under the stated calendar- or fiscal-year due-date rule.source | The alternative corporate income tax applies to taxable years beginning after December 31, 1970.source | The RIC deduction excludes dividends attributable to income not taxed when earned and disallows a dividends-received deduction; the NOL deduction is also unavailable.source |
| MT 3/3 | An electing pass-through entity is a partnership or S corporation; Montana's partnership definition expressly includes a federally partnership-classified LLC.source | The complete PTET provisions and their entity and source-income cross-references state no holding- or passive-activity carve-out.source | The reviewed PTET scope states no assets, receipts, ownership, or activity threshold for a holding-company treatment.source | Each electing partnership or S corporation pays Montana entity tax on the stated affected-owner Montana-source-income base.source | Every electing pass-through entity pays the entity tax under the universal imposition; complete search found no holding/passive exception.source | The election is annual, irrevocable for the year, and due by the extended return deadline; the entity designates an authorized Montana representative.source | The complete four-section PTET subpart states annual operation but no effective or sunset date in its operative text.source | The complete PTET provisions state no holding-income or holding-entity limit on the universal electing-entity imposition.source |
| NC 1/3 | A domestic or authorized foreign LLC is covered when classified as a corporation for federal income-tax purposes.source | The income computation deducts specified foreign-source dividends and specified federal inclusions, net of related expenses.source | The deductions apply to the quoted dividends and federal inclusions to the extent included in federal taxable income, net of related expenses.source | State net income tax applies to every C corporation doing business in North Carolina; the 2026 rate shown is 2%.source | Specified dividend and foreign-income amounts are deducted from federal taxable income, net of related expenses.source | A corporation generally files its return by the fifteenth day of the fourth month after its income year closes.source | Section 105-130.3 lists 2.25% for 2025, 2% for 2026, 1% for 2028, and 0% after 2029.source | Expenses related to untaxed income remain nondeductible; for untaxed dividends, the expense adjustment is capped at 15% of the dividends.source |
| NC 2/3 | For franchise-tax purposes, corporation includes an LLC electing federal corporate tax treatment, but otherwise excludes an LLC.source | The holding-company test covers controlled ownership interests, controlled-company gross income, and specified intellectual property or royalty income.source | A corporation qualifies under any one of § 105-120.2(c)'s three tests, including the quoted 50%, 80%, ownership, and manufacturer-revenue conditions.source | An annual franchise tax applies to corporations; a corporation meeting § 105-120.2's holding-company test uses that section's special rate and limits.source | A qualifying holding company pays under § 105-120.2's special base limits and is not also taxed under the general § 105-122 rule.source | A corporation meeting the holding-company test must file a return, determine total net worth, and apportion that net worth to North Carolina.source | For taxable years beginning on or after January 1, 2025, § 105-120.2(b) sets the quoted rate, first-$1-million maximum, overall maximum, and minimum.source | The general § 105-122 franchise tax does not apply to a business taxed under the holding-company provision, § 105-120.2.source |
| NC 3/3 | The definitions cover a federally partnership-classified LLC as a partnership and a corporate-classified LLC with a valid federal S election as an S corporation.source | No holding-activity or passive-income carve-out was located in the complete taxed-S-corporation and taxed-partnership election sections.source | No operative holding-entity or passive-income qualifying test was located in §§ 105-131.1A and 105-154.1.source | An electing taxed S corporation or taxed partnership pays annual tax on North Carolina taxable income at the § 105-153.7 rate.source | No holding-entity or passive-income carve-out was located in the two election sections; the regime is elective.source | The election is made on the entity's timely filed return and cannot be made or revoked after that return is filed.source | The current taxed-S-corporation and taxed-partnership election language applies to taxable years beginning on or after January 1, 2023.source | A publicly traded partnership described in Code § 7704(c), or a partnership with an unlisted partner type, cannot make the election.source |
| ND 1/1 | A multi-member LLC not federally treated as a partnership and a single-member LLC federally treated as a corporation receive corporate state-tax classification.source | The combined-report rule addresses common control through voting stock and dividends received from a corporation whose assets are included in the combined computation.source | Two or more corporations liable to report must have substantially all voting stock owned or controlled by the same interests, and the dividend payer's assets must be included.source | North Dakota imposes an annual tax on the taxable income of every domestic and foreign corporation.source | In the permitted or required combined computation, dividends from a corporation whose assets are included may not be included in income.source | A corporation receiving § 57-38-14 source income must return; a foreign loan and investment company with solely exempt state income may use the stated affidavit rule.source | The current corporate levy, LLC-classification, combined-report dividend, and filing provisions do not state an effective or sunset period.source | The dividend exclusion is limited to a combined report under the common-control test and to dividends from a corporation whose assets are included in the segregations.source |
| NE 1/2 | The Department treats an entity taxed as a corporation under the Internal Revenue Code, including a corporate-classified LLC, as a corporation for Nebraska corporate income tax.source | No general holding- or passive-activity carve-out was located in the complete corporate imposition statute, regulations, or Department FAQ.source | The searched corporate sources state no qualifying test that excludes an ordinary holding LLC from the regime.source | Nebraska imposes income tax on the taxable income of every corporate taxpayer doing business in the state.source | The general rule reaches a corporate-classified entity with Nebraska-source federal taxable income; no general holding/passive carve-out was located.source | Each corporate taxpayer files one Nebraska income-tax return for each taxable year.source | The current statute states schedules for tax years beginning in 2026 and for tax years beginning on or after January 1, 2027.source | The Department lists Public Law 86-272-protected corporations, S corporations, and financial institutions as outside Nebraska corporate income tax; it states no general holding-company exclusion.source |
| NE 2/2 | Eligible entities include an LLC treated federally as a partnership and an LLC subject to federal subchapter S taxation.source | No holding- or passive-activity carve-out was located in the complete partnership PTET statute, S-corporation PTET statute, or Department PTET guidance.source | The PTET statutes and guidance state no separate qualifying test for a holding or passive entity.source | An eligible partnership or S corporation may irrevocably elect for a tax year to pay Nebraska income tax at the entity level.source | An eligible electing LLC pays entity-level tax on Nebraska-apportioned or allocated net income; no holding-entity carve-out from that elective base was located.source | A current-year election is made on Form PTET-E or by checking box 5 on the applicable income-tax return, and box 5 remains required if Form PTET-E was submitted.source | The Department states that eligible partnerships and S corporations may elect PTET for tax years beginning on and after January 1, 2018.source | The partnership election excludes publicly traded partnerships, and the S-corporation election is limited to entities subject to federal subchapter S taxation; a disregarded LLC is outside both stated classifications.source |
| NH 1/2 | A 'business organization' subject to BPT includes a limited liability company formed under RSA 304-C or a qualifying foreign LLC, taxed as the entity would be taxed for federal purposes.source | The BPT carve-out is limited to a holding entity that is a regulated investment company, an Investment Company Act 'investment company' (or would be but for its 3(c)(1)/(c)(7) exception), or a BFA-linked development entity.source | To be excluded from BPT as a qualified investment company, the LLC must limit its activities to investment activities and elect by the 15th day of the 3rd month of the taxable period.source | New Hampshire taxes the business profits of every business organization, including an LLC, at 7.5 percent for taxable periods ending on or after December 31, 2023.source | An LLC that elects and qualifies as a 'qualified investment company' is excluded from BPT at the entity level; an LLC that does not so qualify is taxed as any other business organization.source | A business organization with gross business income over $92,000 (DRA-adjusted to $109,000 for periods beginning on/after 2025-01-01) must file a BPT return; an electing qualified investment company instead files its own report.source | The current 7.5 percent BPT rate applies to taxable periods ending on or after December 31, 2023; no sunset date is stated.source | The qualified-investment-company exclusion is limited to activities consistent with the company's investment purpose; its 3(c)(7)-based alternative is available only to issuers owned by qualified-purchaser-type investors.source |
| NH 2/2 | A 'business enterprise' subject to BET includes a limited liability company; the tax is measured by the enterprise's compensation, interest and dividends paid, not its income.source | The BET carve-out is limited to a holding entity that is a regulated investment company, an Investment Company Act 'investment company' (or would be but for its 3(c)(1)/(c)(7) exception), or a BFA-linked development entity.source | To be excluded from BET as a qualified investment company, the LLC must limit its activities to investment activities and must have elected qualified-investment-company status under RSA 77-A:5-b.source | New Hampshire taxes the enterprise value tax base (compensation, interest and dividends paid) of every business enterprise, including an LLC, at 0.55 percent for periods ending on/after December 31, 2022.source | An LLC that qualifies as a 'qualified investment company' is excluded from BET at the entity level; an LLC that does not so qualify is taxed as any other business enterprise.source | A business enterprise with gross receipts or an enterprise value tax base over $250,000 (DRA-adjusted to $298,000 for periods beginning on/after 2025-01-01) must file a BET return.source | The current 0.55 percent BET rate applies to taxable periods ending on or after December 31, 2022; no sunset date is stated.source | The qualified-investment-company exclusion is limited to activities consistent with the company's investment purpose; its 3(c)(7)-based alternative is available only to issuers owned by qualified-purchaser-type investors.source |
| NJ 1/4 | The statutory corporation definition includes any other entity classified as a corporation for federal income tax purposes.source | Investment-company treatment covers corporations whose business is at least 90% holding, investing, and reinvesting in the listed securities for their own account.source | The investment-company definition applies a 90% business test and a 90% New Jersey average-gross-asset test, with dealer and specified financial-company exclusions.source | The Corporation Business Tax is a franchise tax on domestic corporations and taxable foreign corporations.source | A qualifying noncaptive investment company enters 40% of the ordinary tax-base line; the current instructions separately require the minimum-tax computation.source | Every corporation acquiring taxable status in New Jersey must file a Corporation Business Tax return.source | The captive-investment-company limitation applies to privilege periods ending on and after July 31, 2023.source | For periods ending on and after July 31, 2023, captive investment companies are taxed as C corporations and do not receive subsection 5(d) treatment.source |
| NJ 2/4 | New Jersey treats federally partnership-classified LLCs as partnerships under the Gross Income Tax Act.source | The investment-club exception covers an all-individual-owner partnership whose assets are securities, cash, or cash equivalents and that meets the other stated limits.source | The current investment-club test requires federal partnership classification, only individual owners, only securities/cash/cash equivalents, the indexed asset ceiling, and no SEC registration requirement.source | The filing fee applies to federally partnership-classified entities with New Jersey-source income or loss and more than two owners, other than investment clubs.source | An investment club meeting the current stated test is exempt from the annual partnership filing fee.source | A partnership with New Jersey-source income or loss, or any New Jersey resident partner, must file Form NJ-1065.source | The cited instructions apply to calendar year 2025 and fiscal years beginning in 2025.source | The current instructions exclude qualifying investment clubs; the general fee rule also requires New Jersey-source income or loss and more than two owners.source |
| NJ 3/4 | Federally partnership-classified LLCs are treated as partnerships under the New Jersey Gross Income Tax Act.source | Qualified investment partnership status covers the listed dividends, interest, securities-loan payments, securities and commodity gains, and similar investment or trading income.source | The qualified-investment-partnership test requires more than 10 members, no member over 50%, at least 90% qualifying gross income, and no dealer-in-securities status.source | A partnership outside the listed exclusions must remit tax on allocated entire net income shares of nonresident partners.source | N.J.S.A. 54:10A-15.11 excludes qualified investment partnerships and investment clubs from the partnership payment rule.source | Form NJ-CBT-1065 must be filed when the entity must calculate tax on nonresident partners.source | The cited partnership instructions apply to calendar year 2025 and fiscal years beginning in 2025.source | The regime does not reach a qualifying investment club whose current adjusted asset ceiling is the lesser of $442,000 or $61,900 per owner.source |
| NJ 4/4 | The BAIT statute defines an eligible LLC as one federally classified as a partnership or S corporation.source | Current PTE-100 instructions recognize hedge-fund status for an investment entity whose only activity is purchasing, holding, or selling intangible personal property not held for customers.source | No separate holding- or passive-entity qualifying test appears in the complete current N.J.S.A. 54A:12 chapter.source | An eligible pass-through entity may annually elect to pay PTE/BAIT at the entity level.source | The complete current BAIT chapter states no separate holding- or passive-entity treatment.source | Every pass-through entity that made the election must file Form PTE-100.source | PTE/BAIT applies for taxable years beginning on or after January 1, 2020.source | The election requires at least one individual, estate, or trust member liable under the Gross Income Tax Act on distributive proceeds.source |
| NM 1/3 | For corporate-income-tax purposes, the statutory corporation definition includes an LLC taxed as a corporation under the Internal Revenue Code.source | New Mexico base income starts with federal taxable income after the IRC §§ 241-249 special deductions, which include the federal dividend-deduction provisions.source | The operative base rule retains the IRC §§ 241-249 special deductions and states no separate New Mexico percentage threshold.source | Corporate income tax applies to a corporation doing business in New Mexico or deriving income from New Mexico property or employment.source | A corporation-classified LLC remains in the regime, but its New Mexico base begins after the federal special deductions in IRC §§ 241-249.source | A covered corporation must file the prescribed return and pay by the due date of its federal corporate income-tax return.source | The 2026 base-income amendment was effective May 20, 2026 and applies to taxable years beginning on or after January 1, 2027.source | The federal-special-deduction base rule does not remove state or local bond interest exempt under the IRC; New Mexico adds that interest back.source |
| NM 2/3 | Revenue guidance expressly includes LLCs among pass-through entities; § 7-3A-10 defines the electing entity by federal pass-through treatment.source | Distributed net income deducts qualifying net capital gains allocated to owners subject to the Income Tax Act.source | The deduction requires net capital gain deductible under § 7-2-34 and proper allocation to owners subject to the Income Tax Act.source | A pass-through entity may elect annually to pay entity-level tax; the tax is imposed on distributed net income.source | The entity remains subject to elective tax, but qualifying net capital gain is removed from distributed net income.source | The election is made by filing a complete entity-level return by the original or extended due date of the federal partnership or S-corporation return.source | The 2023 entity-level-tax amendments apply to taxable years beginning on or after January 1, 2023.source | The holding-income deduction is limited to qualifying net capital gain allocated to Income Tax Act owners; it is not stated as a general passive-income exclusion.source |
| NM 3/3 | The Gross Receipts and Compensating Tax Act definition of person expressly includes a limited liability company.source | The statute exempts receipts from specified interest, dividends, and sales of stocks, bonds, or securities.source | The receipt-category exemption is categorical and states no ownership, income-percentage, or asset-percentage threshold.source | Gross receipts tax is imposed on a person engaging in business in New Mexico, subject to the Act's exemptions and deductions.source | An LLC remains within the gross-receipts regime, but the listed interest, dividend, and securities-sale receipts are exempt.source | Revenue provides a gross-receipts reporting form and recommends electronic filing through Taxpayer Access Point; tax is due by the following month's twenty-fifth day.source | The dividends, interest, and securities-sale exemption has been effective since July 1, 1969.source | The exemption is receipt-specific: interest on money loaned or deposited, dividends or interest from securities, and proceeds from securities sales.source |
| NV 1/2 | Business entities include limited-liability companies and holding companies, among other listed forms, subject to the exclusions in NRS 363C.020(2), which include passive entities.source | Passive income: dividends, interest, LLC income, securities and real property gains, mineral royalties; or in-state activity confined to managing intangible investments such as stocks, bonds, patents.source | Excluded: a passive entity (an LLC with at least 90% of federal gross income from listed passive income and no more than 10% from an active trade or business) or a person confined to intangible investments.source | Nevada imposes the commerce tax, for the privilege of engaging in a business in the State, on each business entity whose Nevada gross revenue in a taxable year exceeds $4,000,000.source | An LLC that meets the passive-entity test, or whose in-state activities are confined to owning and managing intangible investments, is not a business entity and so is outside the commerce tax.source | A return is due 45 days after a taxable year with Nevada gross revenue over $4,000,000; the Department says exempt entities need not register, and registered ones over $4,000,000 may file an exempt-status form.source | Neither NRS ch. 363C nor NAC ch. 363C states an effective or sunset date for the commerce tax or its passive-entity and intangible-investment exclusions.source | Rent is not passive income; holding intangible assets used in a related entity's active trade or business is an active trade or business; a holding company is a business entity unless NRS 363C.020(2) applies.source |
| NV 2/2 | Covers non-natural persons trading for profit, certain natural persons and entities organized under NRS Title 7 whether or not for profit, less listed exclusions; domestic and foreign LLCs declare ch. 76 compliance.source | No holding, passive-investment or intangible-income carve-out from the state business license or its fee was located in NRS ch. 76 or the LLC Act.source | No qualifying test exists to quote: no holding or passive-entity carve-out from the state business license or its fee was located in NRS ch. 76 or the LLC Act.source | No person may conduct a business in Nevada without a state business license; a fee accompanies the application, and an annual renewal fee is due with the annual list for entities that file one.source | Reaches entities organized under NRS Title 7 whether or not for profit, and each LLC list declares ch. 76 compliance; no holding or passive carve-out was located; the no-business fee waiver names only natural persons and partnerships.source | An LLC obtains the license when it files its initial or annual list and renews it with each annual list; a person claiming exclusion or exemption applies annually for a certificate of exemption.source | NRS ch. 76 states no effective or sunset date for the state business license or its fee.source | No holding or passive-entity carve-out from the state business license or its fee was located, so no limits of such a carve-out are stated.source |
| NY 1/3 | The Article 9-A definition of corporation expressly includes a limited liability company within an association under IRC §7701(a)(3).source | The statute defines investment capital as stock investments satisfying the complete asset, holding-period, disposition, dealer-stock, and identification requirements in §208(5)(a).source | Investment capital must satisfy each condition in §208(5)(a), including the holding-period and record-identification rules and the stated exclusions for unitary, combined-report, and issuer stock.source | Article 9-A annually imposes franchise tax on every domestic or foreign corporation within the stated New York nexus rules, except corporations specified in §209(4).source | Article 9-A defines business income as entire net income minus investment income and other exempt income, subject to the stated limit and qualified-financial-instrument election.source | Every Article 9-A taxpayer must transmit an annual report by the statutory due date and file a cessation report for periods not previously reported.source | The business-income-base provision states the general post-2015 period and a separate 2021-through-2029 rule for taxpayers above the stated business-income-base threshold.source | The investment-capital definition excludes stock in a unitary corporation, stock covered by the common-ownership combined-report election, and stock issued by the taxpayer.source |
| NY 2/3 | The filing-fee provision names subchapter K LLCs and federally disregarded LLCs, as well as partnerships with New York-source income.source | No holding- or passive-activity carve-out was located in the complete LLC filing-fee provision, §658(c)(3)(A)-(E).source | The complete filing-fee provision states no separate qualifying test for a holding or passive LLC.source | Section 658(c)(3) requires every subchapter K LLC and every federally disregarded LLC, plus specified partnerships with New York-source income, to pay an annual filing fee.source | The provision reaches every subchapter K LLC and every disregarded LLC and states a filing fee even for a disregarded LLC; no holding-activity carve-out is stated.source | The filing-fee payment is due by the fifteenth day of the third month following the close of the taxable year.source | The provision states that the current minimum and disregarded-LLC filing fee apply for taxable years beginning in 2008 and thereafter.source | The under-one-million-dollar exemption stated in §658(c)(3)(B) is limited to partnerships other than limited liability partnerships and foreign limited liability partnerships; the same paragraph states an LLC minimum fee.source |
| NY 3/3 | Article 24-A expressly includes qualifying LLCs treated federally as partnerships or S corporations within its eligible entity definitions.source | No holding- or passive-activity carve-out was located in the complete Article 24-A section bodies, §§860-866.source | Article 24-A states no separate qualifying test for a holding or passive entity after a complete search of §§860-866.source | Article 24-A imposes tax for each taxable year on the pass-through entity taxable income of every electing partnership and electing S corporation.source | The taxable-income definition reaches the stated owner-level income, gain, loss, and deduction items; no holding-entity carve-out was located in Article 24-A.source | Each electing partnership and electing S corporation must file its Article 24-A return by March fifteenth following the close of the stated year.source | The annual election is due by the first estimated-payment due date, applies to the current taxable year, and becomes irrevocable after that due date.source | The eligible-partnership definition excludes a publicly traded partnership and requires the Article 22 filing obligation; eligible S corporations must be New York S corporations subject to Article 9-A.source |
| OH 1/3 | The CAT reaches 'person,' a non-exhaustive list that names limited liability companies directly, alongside partnerships, corporations and other entities.source | The CAT's gross-receipts base excludes interest income (other than credit-sale interest), dividends/distributions from corporations, and a pass-through entity's distributive or proportionate shares from another pass-through entity.source | The operative exclusions are interest income (not credit-sale interest), corporate dividends/distributions and pass-through distributive shares, and proceeds from disposing of an IRC section 1221 or 1231 asset regardless of holding period.source | Ohio levies a commercial activity tax on each person with taxable gross receipts for the privilege of doing business in Ohio.source | The CAT reaches a holding LLC's gross receipts; the exclusions name only interest (non-credit-sale), dividends/distributions and pass-through distributive shares, leaving other examples of gross receipts unaffected.source | A person with not more than $150,000 of taxable gross receipts for the calendar year is an 'excluded person,' not a 'taxpayer' required to register or pay the CAT.source | R.C. 5751.02 is current as last amended effective June 15, 2026 (Senate Bill 450); no sunset or expiration text was located for the CAT or its gross-receipts exclusions.source | No stated limit on the gross-receipts exclusions themselves was located in R.C. 5751.01(F)(1)-(2).source |
| OH 2/3 | A 'qualifying pass-through entity' is a pass-through entity (an LLC taxed federally as a partnership or S corp qualifies) excluding tax-exempt persons, publicly traded partnerships, and REIT/RIC/REMIC entities.source | An IPTE's qualifying income includes intangible-property transaction/loan/financing fees, dividend/interest income, net capital gains on intangible property, and distributive shares from other PTEs.source | Two quarterly-average 90% thresholds (intangible-source gross income; intangible net book value) qualify an IPTE to exclude that income from its adjusted qualifying amount, except net management fees above 5% of net income.source | Ohio levies a withholding tax on every qualifying pass-through entity with at least one individual qualifying investor, on the sum of its investors' adjusted qualifying amounts, if nexus exists and that sum exceeds $1,000.source | An LLC that qualifies as an IPTE is still a qualifying pass-through entity subject to R.C. 5747.41, but computes a different (excluded) adjusted-qualifying-amount base for its holding-type income.source | No withholding tax applies unless the entity's investors' adjusted qualifying amounts exceed $1,000; a qualifying entity otherwise files its annual return by the 15th day of the fourth month after its taxable year ends.source | R.C. 5747.41 is current as last amended effective June 14, 2022; no sunset or expiration text was located for the withholding tax or the IPTE carve-out.source | The IPTE exclusion does not cover net management fees once they exceed five percent of the entity's GAAP net income; that portion stays in the adjusted qualifying amount.source |
| OH 3/3 | Only a qualifying pass-through entity that is NOT a disregarded entity (so a single-member LLC taxed as disregarded cannot elect) and that files a timely election becomes an electing pass-through entity.source | No holding or passive-income carve-out from the electing pass-through entity's qualifying taxable income was located in R.C. 5747.38 or 5747.39.source | No qualifying test exists to quote: no holding or passive carve-out from the electing tax's base was located in R.C. 5747.38 or 5747.39.source | An electing pass-through entity (an LLC that elects) is taxed on its qualifying taxable income at the rate equal to Ohio's top business-income individual rate.source | Qualifying taxable income cross-references only the (A)(2)-(7) adjustments of R.C. 5733.40, not the (A)(1) 'subject to section 5733.401' language that carries the withholding tax's IPTE exclusion.source | An eligible pass-through entity elects by filing a prescribed form on or before the R.C. 5747.42 return deadline; the election is irrevocable for that year and applies only to that year.source | R.C. 5747.38 is current as last amended effective September 30, 2025 and has applied since taxable years beginning in 2022; no sunset or expiration text was located.source | No stated carve-out exists whose limits could be quoted; full-text search of R.C. 5747.38 and 5747.39 located no holding or passive provision at all.source |
| OK 1/2 | Oklahoma adopts federal tax status and elections unless its Income Tax Act says otherwise, placing an LLC with federal corporate status in the corporate class.source | No general holding- or passive-activity carve-out was located in the complete Oklahoma Income Tax Act.source | No operative holding- or passive-entity carve-out test was located for Oklahoma corporate income tax.source | Oklahoma imposes corporate income tax on the Oklahoma taxable income of every corporation doing business in the state or deriving income from Oklahoma sources.source | Section 2355(H) taxes every corporation meeting its business-or-income scope; the complete-act search located no general holding-company exemption.source | Every corporation files an annual return stating taxable income and the Oklahoma adjustments, signed by the specified corporate officer.source | The current corporate rate provision applies to taxable years beginning after December 31, 2021.source | Oklahoma states that no additional income tax is imposed on accumulated taxable income or undistributed personal-holding-company income; the general corporate tax remains stated separately.source |
| OK 2/2 | The statutory pass-through entity list expressly includes an LLC whose items pass through under federal Subchapter K or S.source | No holding- or passive-activity carve-out was located in the complete Pass-Through Entity Tax Equity Act provisions.source | No operative holding- or passive-entity carve-out test was located for the elective pass-through entity tax.source | Oklahoma levies the pass-through entity tax on each electing pass-through entity for tax years beginning on or after January 1, 2022.source | The elective tax applies to Oklahoma net entity income without a separately stated holding- or passive-entity treatment.source | The tax is due with the electing entity's Oklahoma income-tax return; the election is available to entities required to file an Oklahoma partnership or S-corporation return.source | The current pass-through entity tax calculation applies to tax years beginning on or after January 1, 2022.source | The elective tax base is limited to the positive or negative sum of the entity's Oklahoma income, gain, loss, and deduction under the Oklahoma Income Tax Act.source |
| OR 1/4 | For chapters 317 and 318, an Oregon or qualified foreign LLC is classified in the same manner as for federal income-tax purposes.source | Oregon taxable income receives a 70-percent subtraction for qualifying dividends included in federal taxable income, subject to ORS 317.267's conditions.source | The complete test adds back specified federal dividend/GILTI deductions, applies the 70/80/100-percent subtraction rules, and excludes the subtracted amount from the Oregon sales factor.source | Oregon imposes the Corporation Excise Tax under ORS 317.070 on the corporations and Oregon income stated in that provision.source | A corporate-classified holding LLC receives different base treatment through the statutory subtraction for qualifying dividends included in federal taxable income.source | A chapter 317 or 318 return is due on the 15th day of the month following the corresponding federal-return due date.source | No current effective or sunset period for the Corporation Excise Tax regime or ORS 317.267 dividend treatment was stated in the complete chapter search.source | The dividend subtraction is unavailable for specified non-dividend items, federal-disallowance categories and foreign-source dividend income; an insurer rule uses a 100-percent substitution.source |
| OR 2/4 | For chapters 317 and 318, an Oregon or qualified foreign LLC is classified in the same manner as for federal income-tax purposes.source | Oregon taxable income receives a 70-percent subtraction for qualifying dividends included in federal taxable income, subject to ORS 317.267's conditions.source | The complete test adds back specified federal dividend/GILTI deductions, applies the 70/80/100-percent subtraction rules, and excludes the subtracted amount from the Oregon sales factor.source | Oregon imposes the Corporation Income Tax under ORS 318.020(1) on the corporations and Oregon income stated in that provision.source | A corporate-classified holding LLC receives different base treatment through the statutory subtraction for qualifying dividends included in federal taxable income.source | A chapter 317 or 318 return is due on the 15th day of the month following the corresponding federal-return due date.source | No current effective or sunset period for the Corporation Income Tax regime or ORS 317.267 dividend treatment was stated in the complete chapter search.source | The dividend subtraction is unavailable for specified non-dividend items, federal-disallowance categories and foreign-source dividend income; an insurer rule uses a 100-percent substitution.source |
| OR 3/4 | The CAT definition of person expressly includes LLCs, partnerships, corporations, trusts and federally disregarded entities.source | Commercial activity excludes ordinary interest, IRC 1221/1231 asset-disposition receipts, dividends and pass-through distributive income, subject to quoted exceptions.source | The statutory test is categorical: the quoted receipts are outside commercial activity, while credit-sale and financial-institution interest are exceptions to the interest exclusion.source | Oregon imposes an annual Corporate Activity Tax on each person with taxable commercial activity and substantial Oregon nexus.source | CAT applies to taxable commercial activity, while the quoted holding receipts are excluded and the quoted interest exceptions remain outside that exclusion.source | A person doing business in Oregon with annual commercial activity over $1 million must file by the 15th day of the fourth month after the tax year ends.source | The Corporate Activity Tax provisions apply to tax years beginning on or after January 1, 2020.source | The quoted interest, asset-disposition, dividend and pass-through-distribution receipts do not enter commercial activity, subject to the two stated interest exceptions.source |
| OR 4/4 | The elective regime defines pass-through entity to include a partnership, S corporation or LLC electing partnership or S-corporation treatment.source | No holding, passive-investment or intangible-income carve-out was located in the scoped pass-through tax provisions and current amendments.source | No qualifying test exists to quote because no holding or passive-entity carve-out was located in the scoped pass-through tax provisions.source | An eligible pass-through entity may elect Oregon's Pass-Through Business Alternative Income Tax when its members satisfy the stated individual-ownership conditions.source | No holding carve-out was located; the elective tax base expressly uses distributive proceeds that include dividends, royalties, interest, rents and gains.source | An electing pass-through entity must file an entity tax return with payment by the chapter 316 return date provided in ORS 314.385.source | The elective tax applies to tax years beginning on or after January 1, 2022, and before January 1, 2028.source | No holding or passive-entity carve-out was located, so the scoped provisions state no limits of such a carve-out.source |
| PA 1/2 | Article IV's corporation definition includes an LLC classified as a corporation for federal income-tax purposes.source | Business activity includes licensing intangibles, customer transactions involving intangibles, loans, and sales of intangibles used in Pennsylvania.source | The dividend modification is limited, for tax years beginning after 1990, to stated federal §78 amounts and qualifying foreign-corporation dividends.source | Article IV imposes an excise tax on a corporation exercising listed Pennsylvania privileges.source | Corporate taxable income receives the dividend modification stated in §401(3)1(b).source | For tax years beginning after 2020, the Article IV report is due on the fifteenth day of the month following the federal return due date.source | The Article IV rate schedule states an ongoing period beginning January 1, 2031, after its intervening dated periods.source | For tax years beginning after 1990, the stated dividend modification is limited to §78 amounts and qualifying foreign-corporation dividends.source |
| PA 2/2 | A Pennsylvania S corporation is a federal S corporation without a valid Pennsylvania opt-out election; Article IV includes an LLC federally classified as a corporation.source | This branch is defined by net recognized built-in gain determined under federal §1374(d)(2).source | The branch applies from 1998 and uses federally determined net recognized built-in gain under §1374(d)(2).source | For a Pennsylvania S corporation, Article IV taxable income is federally determined net recognized built-in gain.source | For a Pennsylvania S corporation, Article IV substitutes federally determined net recognized built-in gain as taxable income.source | A Pennsylvania S-corporation return is due thirty days after the federal corporate income-tax return due date.source | The Pennsylvania S-corporation built-in-gain taxable-income rule applies to taxable years beginning on or after January 1, 1998.source | The Article IV taxable-income definition reaches only net recognized built-in gain as federally determined under §1374(d)(2).source |
| RI 1/3 | This annual-charge branch covers an LLC not treated as a corporation for federal income-tax purposes.source | Unknown Verified absenceThe checked source text does not state the row-specific detail needed for this value.source | Unknown Verified absenceThe checked source text does not state the row-specific detail needed for this value.source | A Rhode Island LLC not treated as a corporation federally must pay the annual charge described in §7-16-67(c)(2).source | Rhode Island's annual charge reaches every LLC not taxed as a corporation, with no holding or passive-activity exception in the LLC Act.source | The LLC return is due when its federal return is due, without regard to extension (§7-16-67(b)).source | The current LLC return rule applies for tax years on or after January 1, 2016 (§7-16-67(b)).source | Unknown Verified absenceThe checked source text does not state the row-specific detail needed for this value.source |
| RI 2/3 | This branch covers an LLC treated as a corporation for federal income-tax purposes (§7-16-67(c)(1)).source | The holding provisions address securities held on the corporation's own behalf and an intangible-investment class with collection and distribution of investment income.source | The securities adjustment requires own-account activity and at least 90% of receipts; the separate corporation-definition exception requires five Rhode Island employees and an office.source | A federally corporate LLC pays the chapter 44 business corporation tax; §44-11-2(a) imposes tax on corporate net income.source | Section 44-11-2 changes the computation for a qualifying securities holder and named investment vehicles, while subsection (e) retains a minimum tax.source | The LLC return is due when its federal return is due, without regard to extension (§7-16-67(b)).source | The current net-income rate clause applies for tax years beginning on or after January 1, 2015 (§44-11-2(a)).source | The 90%-receipts adjustment excludes broker, underwriter, and distributor activity; the separate intangible-investment exception is worded only for qualifying corporations.source |
| RI 3/3 | The elective PTE regime includes an LLC not taxed as a corporation for federal tax purposes.source | The PTE net-income definition expressly excludes specially allocated investment income.source | The entity elects tax on the statute's defined net income, which excludes specially allocated investment income (§44-11-2.3(a)(2), (b)(1)).source | A qualifying pass-through entity may elect to pay Rhode Island tax at the entity level (§44-11-2.3(b)(1)).source | The elective tax applies to defined PTE net income, and that definition excludes specially allocated investment income; this is different base treatment, not an exemption.source | The annual election is made by filing the prescribed tax form and remitting the appropriate tax (§44-11-2.3(a)(1)).source | The elective entity-level tax applies for tax years beginning on or after January 1, 2019; the cited current version is effective January 1, 2025.source | The elective PTE tax base does not include specially allocated investment income under §44-11-2.3(a)(2).source |
| SC 1/3 | For South Carolina tax titles, “corporation” includes an LLC taxed as a corporation.source | No general holding- or passive-entity activity carve-out was located in Chapter 6 for the corporate income tax.source | No operative holding- or passive-entity carve-out test was located for the corporate income tax.source | South Carolina imposes corporate income tax on every corporation and other entities using federal corporate rates when the stated nexus or income test is met.source | Section 12-6-530 uses universal corporate-classification language; no general holding-entity carve-out was located in Chapter 6.source | A corporation subject to Chapter 6 files a return; the statute separately states when an S corporation must file.source | No effective or sunset period for § 12-6-530 is stated in its history or the complete Chapter 6 search.source | An S corporation is outside Chapter 6 tax to the extent it is exempt from federal corporate income tax; shareholder inclusion remains stated separately.source |
| SC 2/3 | The Chapter 2 tax definition includes a corporation-taxed LLC in “corporation”; Chapter 20 reaches the stated domestic, foreign, and return-filing corporations.source | The holding-company provision concerns parent capital contributions used to finance a subsidiary expansion in an Economic Impact Zone.source | The reduction requires qualifying parent capital, a subsidiary expansion above the stated threshold, an Economic Impact Zone, and timely completion.source | Every corporation required to file the annual report pays the corporate license fee, which Chapter 20 deems a tax.source | A qualifying holding company may reduce the specified paid-in capital surplus, while § 12-20-50(A) still states the annual fee and minimum.source | Covered corporations file an annual report with the Department of Revenue by the stated fourth-month deadline.source | The § 12-20-50(C) holding-company reduction applies to the stated increases in capital on January 1, 2003, and thereafter.source | The holding-company reduction is limited to the attributed parent contribution, qualifying subsidiary expansion, zone, and completion conditions stated in § 12-20-50(C).source |
| SC 3/3 | A qualified entity includes a partnership or S corporation, including an LLC taxed as either, when its owners satisfy the statutory ownership test.source | Passive investment income and related expense, plus capital gains and losses, are excluded from active trade or business income.source | The entity-level election reaches active trade or business income, whose definition excludes passive investment income and capital gains or losses.source | A qualified entity may elect annually to have tax imposed on the entity's active trade or business income.source | Passive investment income is outside the elected entity-level active-trade-or-business base; the statute does not label the entity itself exempt.source | The annual election is due with the applicable return; owner exclusion depends on the qualified entity properly filing and paying the elected tax.source | The qualified-entity election first applies to tax years beginning after 2020.source | The active-trade-or-business definition excludes passive investment income, related expense, capital gains and losses, service payments, and stated personal-service amounts.source |
| SD 1/1 | The definitions name LLCs as corporations and persons; the tax reaches an LLC only when it falls within the quoted financial-institution activities or special chapter reach.source | The base and apportionment rules expressly address interest, dividends, obligations, securities, stocks, bonds, money-market instruments, and securities gains.source | The quoted provisions state each federal-base condition, the taxed-financial-institution dividend condition, and the principal-place-of-business sourcing condition.source | Chapter 10-43 imposes an annual tax on each financial institution doing or licensed to do business in South Dakota during any part of its tax year.source | Holding income is treated through stated additions, a limited dividend subtraction, and South Dakota numerator treatment for securities receipts when the principal office is in the state.source | Each taxpayer files the chapter 10-43 return and pays the tax within 15 days after its federal income-tax return is due; delinquency carries statutory penalty and interest.source | The complete current chapter states no operative effective or sunset date for the current holding-income rules or securitization exclusion.source | The dividend subtraction is limited to dividends from chapter-taxed financial institutions; a qualifying financial-institution-owned securitization pass-through is excluded from person status.source |
| TN 1/3 | Franchise taxpayers include limited liability companies and professional LLCs; an LLC whose single member is a corporation is disregarded (Department of Revenue, citing Tenn. Code Ann. § 67-4-2004(36)).source | Exemptions in Tenn. Code Ann. § 67-4-2008(a) that name LLCs and turn on holding securities, affiliate notes or passive investment income: venture capital funds, diversified investing funds, receivables entities and FONCEs.source | Tests quoted: venture capital fund (over 50% non-public securities, over 50% unaffiliated capital); FONCE (95% owned by relatives or their trusts, 66.67% passive income); diversified fund (90% tests); 98%/80% receivables entity.source | Franchise tax (Tenn. Code Ann. § 67-4-2105(a)): a privilege tax on entities doing business in Tennessee with substantial nexus, measured by net worth, as described by the Department of Revenue.source | Exempt from the franchise tax under Tenn. Code Ann. § 67-4-2008 when the LLC meets a quoted exemption test; the Department states the § 67-4-2008 exemptions apply to both the franchise and excise taxes.source | Exempt entities file Form FAE183 (initial application, then annual renewal) by the 15th day of the fourth month after year-end; FONCEs add a Disclosure of Activity; a non-qualifying year requires Form FAE170.source | LLCs were brought within the franchise and excise taxes by the 1999 Tax Revision and Reform Act; FONCE ownership through trusts for family members applies for tax years ending on or after July 1, 2026.source | Stated limits: failing a requirement at any time in the period loses the exemption for the whole period; FONCE excludes corporations, commercial or industrial rents and non-securities gains; funds may not act as brokers.source |
| TN 2/3 | Excise taxpayers include LLCs, named in the Department's taxpayer list and its excise overview; an LLC whose single member is a corporation is disregarded (citing Tenn. Code Ann. § 67-4-2004(36)).source | Exemptions in Tenn. Code Ann. § 67-4-2008(a) that name LLCs and turn on holding securities, affiliate notes or passive investment income: venture capital funds, diversified investing funds, receivables entities and FONCEs.source | Tests quoted: venture capital fund (over 50% non-public securities, over 50% unaffiliated capital); FONCE (95% owned by relatives or their trusts, 66.67% passive income); diversified fund (90% tests); 98%/80% receivables entity.source | Excise tax (Tenn. Code Ann. § 67-4-2007): a tax on the net earnings of persons engaged in business in Tennessee, other than nonprofit and exempt entities, as described by the Department of Revenue.source | Exempt from the excise tax under Tenn. Code Ann. § 67-4-2008 when the LLC meets a quoted exemption test; the Department states an exempt entity is not subject to excise tax and files no excise return.source | Exempt entities file Form FAE183 (initial application, then annual renewal) and no excise return; FONCEs add a Disclosure of Activity; a non-qualifying year requires Form FAE170 with any tax due.source | LLCs were brought within the franchise and excise taxes by the 1999 Tax Revision and Reform Act; FONCE ownership through trusts for family members applies for tax years ending on or after July 1, 2026.source | Stated limits: a requirement failed at any time loses the exemption for the period; FONCE excludes corporations, commercial rents and non-securities gains; taxable owners report exempt-LLC income; § 67-4-2007(f) gains.source |
| TN 3/3 | 'Person' means an individual, firm, partnership, corporation, trust or other group acting as a unit; the Business Tax Manual applies the tax to an LLC and disregards a corporate-owned single-member LLC.source | Exempt services include those furnished by investment trusts, investment companies and holding companies; sales of intangibles such as royalties, stocks, bonds, notes and other securities are not subject to the tax.source | Exempt if the service is one furnished by investment trusts, investment companies, holding companies or commodity trading companies (SIC definitions); sales of stocks, bonds, notes, other securities and royalties are not taxed.source | State-level business tax (Tenn. Code Ann. §§ 67-4-704, 67-4-708): a privilege tax measured by gross sales of tangible personal property and services, as described by the Department of Revenue.source | Exempt from the business tax under Tenn. Code Ann. § 67-4-708(3)(C) for services furnished by holding companies and investment companies; sales of intangibles such as stocks, bonds, notes and royalties are not subject to it.source | For exempt services, including those of holding companies, no business license is needed and no tax is due unless the business also makes taxable sales; persons subject to the tax register before doing business.source | The uniform state-level business tax dates from January 1, 2014 (Public Chapter 313, 2013); the $100,000 filing threshold applies for tax years ending on or after December 31, 2023 (Public Chapter 377, 2023).source | Stated limits: providers of exempt services still owe tax on non-exempt sales of property and taxable services; services to affiliates are taxed on any markup; management services are not an exempt category.source |
| TX 1/1 | Taxable entities include LLCs (Comptroller: single-member and series LLCs too) and holding companies; the Comptroller states federal tax treatment does not determine franchise tax responsibility.source | Passive-entity income: dividends, interest, LLC income, positive partnership shares, listed gains and mineral royalties; the passive-entity exclusion is limited to general or limited partnerships and non-business trusts.source | Passive entity: a general or limited partnership or non-business trust with at least 90% of federal gross income from listed sources and no more than 10% from conducting an active trade or business (§ 171.0004).source | Franchise tax under Tax Code chapter 171, imposed on each taxable entity that does business in Texas or is chartered or organized in Texas.source | Chapter 171 lists LLCs and holding companies as taxable entities; its passive-entity exclusion is limited to general or limited partnerships and trusts other than business trusts.source | A taxable LLC files an annual report unless no tax is due for the period, and a yearly public information report listing corporations, LLCs, LPs and PAs in which it owns a 10% or greater interest, whether or not tax is owed.source | Section 171.001 carries a 1981 Act note (eff. Jan. 1, 1982); the passive-entity definition in § 171.0003 took effect January 1, 2008; no expiration is stated in §§ 171.0002-171.0004 or 171.001.source | Only general or limited partnerships and non-business trusts can be passive; rent and certain affiliated nonoperator mineral income are not passive income; holding intangibles used in a related entity's active business is active.source |
| UT 1/3 | Utah's corporate definition includes organizations taxed as corporations for federal income-tax purposes, which reaches a corporate-classified LLC.source | Utah separately allocates nonbusiness rents, royalties, capital gains, interest, dividends, and patent or copyright royalties.source | Nonbusiness interest and dividends are allocated to Utah when the taxpayer's commercial domicile is in Utah; other holding receipts have their own statutory allocation rules.source | Utah imposes an annual tax on a nonexempt domestic or foreign corporation for exercising its corporate franchise or doing business in Utah.source | Holding receipts receive activity-specific source allocation; qualifying foreign-subsidiary dividends receive a partial subtraction, while investment-held income is excluded from the foreign-operating-company subtraction.source | A C corporation files Utah Form TC-20 for the corporation franchise or income tax.source | The current imposition section is identified in the official Code XML as amended in the 2026 General Session.source | The partial dividend subtraction is limited to a foreign subsidiary that belongs to the unitary group and is omitted from the specified combined reports; investment-held income cannot use the foreign-operating-company subtraction.source |
| UT 2/3 | Utah's corporate definition includes organizations taxed as corporations for federal income-tax purposes, which reaches a corporate-classified LLC.source | Utah separately allocates nonbusiness rents, royalties, capital gains, interest, dividends, and patent or copyright royalties.source | Nonbusiness interest and dividends are allocated to Utah when the taxpayer's commercial domicile is in Utah; other holding receipts have their own statutory allocation rules.source | Utah imposes income tax on a nonexempt corporation's Utah-source taxable income for periods not included in its franchise-tax base.source | Holding receipts receive activity-specific source allocation; qualifying foreign-subsidiary dividends receive a partial subtraction, while investment-held income is excluded from the foreign-operating-company subtraction.source | A C corporation files Utah Form TC-20 for the corporation franchise or income tax.source | The current imposition section is identified in the official Code XML as amended in the 2026 General Session.source | The partial dividend subtraction is limited to a foreign subsidiary that belongs to the unitary group and is omitted from the specified combined reports; investment-held income cannot use the foreign-operating-company subtraction.source |
| UT 3/3 | The pass-through entity definition expressly includes a federally partnership-classified LLC and an S corporation.source | The elective regime distinguishes business income—including integral intangible-property activity—from all other pass-through entity income classified as nonbusiness income.source | Voluntary taxable income includes the stated resident-individual income and Utah-source business and nonbusiness income attributed to nonresident individuals.source | A pass-through entity that is not disregarded may elect to pay tax on voluntary taxable income.source | A qualifying LLC may elect tax on voluntary taxable income, which expressly includes business and nonbusiness income within the stated owner and source rules; no holding/passive carve-out was located.source | Payment by the last day of the taxable year is the irrevocable, nonrefundable election, and the entity must remit by that date.source | The current elective-tax section is identified in the official Code XML as amended in the 2026 General Session.source | A disregarded pass-through entity cannot elect, and the stated elective base is limited to income attributed to final pass-through entity taxpayers who are resident or nonresident individuals.source |
| VA 1/3 | The corporation-income-tax regulation includes any partnership or other entity subject to federal corporation income tax, which reaches an LLC with that federal classification.source | Virginia taxable income subtracts dividends received from a corporation in which the taxpaying corporation owns at least 50% of voting stock.source | The dividend subtraction requires ownership of 50% or more of the distributing corporation's voting stock.source | Virginia annually imposes corporation income tax on every Virginia corporation and every foreign corporation having income from Virginia sources.source | The LLC remains in the corporation-income-tax regime, but qualifying dividends are subtracted from the federal-taxable-income starting point.source | Every Virginia corporation or corporation with Virginia-source income, other than an S corporation filing under § 58.1-392, reports by the fifteenth day of the fourth month after year-end.source | Article 10 states no commencement or sunset date for the 50%-ownership dividend subtraction in Va. Code § 58.1-402(C)(10).source | The dividend subtraction is not a general interest exclusion: specified obligation interest is added back, while a foreign corporation with only secured-note interest and no Virginia activity has no Virginia-source income.source |
| VA 2/3 | The pass-through-entity definition expressly includes LLCs and professional LLCs recognized as separate federal-tax entities whose owners report pass-through items.source | Elective-PTE taxable income incorporates subtractions for income from, or sales or exchanges of, qualifying U.S. and Virginia obligations and securities.source | The electing PTE receives § 58.1-391 adjustments; owner modifications are applied by distributive share, including the stated obligation-income subtractions.source | Virginia annually taxes the Virginia taxable income attributable to eligible owners of every pass-through entity making the annual election.source | The electing LLC remains subject to PTET, but qualifying U.S.- and Virginia-obligation income is subtracted through the incorporated owner-modification rules.source | A pass-through entity doing business in Virginia or receiving Virginia-source income files by the fifteenth day of the fourth month after its taxable year closes.source | For taxable years beginning on or after January 1, 2022, a pass-through entity may make the annual election on its timely filed return.source | The federal-obligation subtraction excludes interest on federal tax refunds, equipment-purchase contracts, and other normal business transactions.source |
| VA 3/3 | Article 16.1 adopts the § 58.1-390.1 PTE definition, which expressly includes an LLC recognized as a separate federal-tax entity with pass-through reporting.source | An investment PTE has at least 95% intangible assets, all income from interest, dividends, and capital gains on intangibles, no income-producing tangible property, and no Virginia trade or business.source | All four definition elements must be met; 'substantially all' means at least 95%. The Department then treats the intangible income as not Virginia-source income.source | A PTE with Virginia-source taxable income allocable to a nonresident owner pays withholding tax for the privilege of doing business in Virginia, subject to subsection C.source | The statute imposes withholding only on Virginia-source income; Public Document 15-240 treats qualifying investment-PTE intangible income as not Virginia-source and requires no withholding payment.source | Public Document 15-240 states that a qualifying investment PTE need not pay the withholding tax or file Form 502.source | The investment-PTE guidance applies to tax years beginning on or after January 1, 2015; statutory PTE withholding liability applies from January 1, 2008.source | The entity treatment does not remove the manager's tax on a Virginia business; royalties from specified intangibles may remain subject to corporate addback or equitable adjustment.source |
| VT 1/6 | The corporation definition reaches a business entity taxed federally as a corporation; the Department expressly includes LLCs electing C-corporation treatment.source | Different treatment is available to an electing digital business entity meeting the no-Vermont-property, payroll, sales, activity, affiliation, and technology-use conditions.source | The digital-business-entity definition states the complete qualification test for the alternative franchise-tax treatment.source | Corporate Income Tax is imposed on income earned or received by every taxable corporation.source | A corporation that qualifies and elects as a digital business entity uses the amount determined under the separate Digital Business Entity Franchise Tax provision.source | Every taxable corporation must file the Vermont corporate income-tax return by the federal-return due date.source | The digital-business-entity election that supplies the different treatment took effect January 1, 2010.source | Section 5838 states that an electing qualifying digital business entity is not subject to section 5832.source |
| VT 2/6 | The definition covers a business entity meeting the full-year affiliation, Vermont-presence, activity, and technology-use conditions and refers expressly to members and partners.source | No separate holding- or passive-activity carveout appears in the complete current provisions governing this franchise tax.source | The complete current digital-business-entity provisions state no separate holding- or passive-entity exemption test.source | An annual franchise tax is imposed on every business entity that qualifies and elects as a digital business entity.source | Every qualifying electing business entity is subject to the annual franchise tax; no holding- or passive-entity carveout is stated.source | The franchise tax is reported and paid in the stated corporate-tax manner, with a federal return copy supplied to the Commissioner.source | The Digital Business Entity Franchise Tax took effect January 1, 2010.source | The regime does not reach a nonelecting entity or one that fails the full-year digital-business-entity conditions.source |
| VT 3/6 | Department guidance applies Business Entity Income Tax to LLCs electing S-corporation treatment.source | The complete current S-corporation subchapter states no holding- or passive-activity carveout from the minimum tax.source | No separate holding- or passive-entity exemption test appears in the complete current S-corporation subchapter.source | An S corporation subject to section 5914 must pay the annual minimum tax.source | Every S corporation subject to section 5914 must pay the annual minimum tax; no holding-entity carveout is stated.source | The S corporation must file an annual return by the prescribed federal S-corporation return due date.source | The current minimum-tax section reflects an amendment effective May 25, 2016.source | No holding- or passive-entity limit beyond the section 5914 scope was stated in the complete current S-corporation subchapter.source |
| VT 4/6 | Section 5921 expressly includes a limited liability company taxed federally as a partnership.source | The exemption covers maintenance and management of intangible investments when both stated ceilings are met.source | The statutory test limits activities to intangible-investment maintenance and management, annual investment income to $5,000, and total assets to $20,000.source | A partnership-classified LLC subject to section 5920 must pay the annual minimum tax.source | A qualifying investment club is exempt from the annual entity tax; the current BI-471 instructions operationalize the same two ceilings.source | A partnership or LLC within section 5920 must file an annual return by its federal-return due date.source | The current minimum-tax section reflects an amendment effective April 29, 1998.source | The tax does not reach a qualifying investment club whose activities and both financial ceilings satisfy section 5921.source |
| VT 5/6 | Department guidance includes LLCs electing S-corporation treatment in Business Entity Income Tax.source | The complete current S-corporation subchapter states no holding- or passive-activity carveout from the nonresident-shareholder payment.source | No separate holding- or passive-entity exemption test appears for the mandatory payment.source | An S corporation is liable for Vermont income taxes imposed on nonresident shareholders with respect to its income.source | The rule makes the S corporation liable with respect to each nonresident shareholder; no holding-entity carveout is stated.source | The entity must file its annual S-corporation return by the prescribed federal due date.source | The current mandatory-payment section reflects an amendment effective January 1, 2023.source | The complete current S-corporation subchapter states no holding- or passive-entity exclusion from subsection 5914(c).source |
| VT 6/6 | Section 5920(c) expressly names partnerships and limited liability companies with nonresident partners or members.source | The complete current section 5920 states no holding- or passive-activity carveout from the nonresident-partner or member payment.source | No separate holding- or passive-entity exemption test appears in the complete current section 5920.source | A partnership or LLC is liable for Vermont income taxes imposed on nonresident partners or members with respect to entity income.source | Section 5920(c) imposes the nonresident-member payment; the complete section states no holding- or passive-entity carveout.source | Section 5920(a) still requires the partnership or LLC annual return by the federal-return due date.source | The current mandatory-payment section reflects an amendment effective January 1, 2023.source | The complete current section 5920 states no holding- or passive-entity exclusion from subsection 5920(c).source |
| WA 1/2 | The tax reaches every 'person' with substantial nexus; RCW 82.04.030 defines 'person' to include, among others, individuals, trusts, estates, copartnerships, corporations and limited liability companies.source | RCW 82.04.4281 deductions: investment income (incidental, or of listed persons such as collective investment vehicles); a parent's dividends or distributions from the capital account from subsidiaries; intercompany loan interest.source | (1)(a) needs investment income under 5% of worldwide gross income; persons listed in (3), e.g. a collective investment vehicle meeting a 3-part test incl. 90% investment income, deduct regardless; (1)(b) states no percentage test.source | Business and occupation (B&O) tax, chapter 82.04 RCW: levied on every person with substantial nexus for the act or privilege of engaging in business activities, measured by value of products, gross proceeds or gross income.source | Gross income includes dividends, interest and trading gains, but a parent may deduct dividends or distributions from the capital account from its subsidiary entities, and listed persons such as CIVs may deduct investment income.source | General return rule for chapter 82.04 taxes: due monthly within 25 days unless DOR sets a longer period (annual returns by April 15); DOR may relieve persons under $125,000 of B&O gross income ($250,000 from Jan. 1, 2029).source | The current RCW 82.04.4281 text (2025 c 420 s 402) took effect January 1, 2026. RCW 82.04.650 (2010 1st sp.s. c 23 s 111) took effect June 1, 2010, subject to that act's contingency clause.source | Not deductible under (1)(a) or (3): loan and credit income other than the (1)(c) item, and amounts received by banking, lending or security businesses; (1)(a) requires investment income under 5%; (4) lists CIV exclusions.source |
| WA 2/2 | A partnership, LLC or S corporation that reports out distributive shares of taxable income for federal income tax purposes may elect; for an LLC, a person authorized to sign its return makes the election.source | No holding, passive-investment or intangible-income carve-out from the pass-through entity tax was located in chapter 82A.04 RCW.source | No qualifying test exists to quote: no holding or passive-entity carve-out from the pass-through entity tax was located in chapter 82A.04 RCW.source | Elective pass-through entity tax: beginning January 1, 2028, imposed on an electing entity's taxable income for each taxable year in which its election is in effect, and paid by the electing entity.source | No holding or passive-entity carve-out located; RCW 82A.04.520(3)(c) includes investment income in an electing entity's taxable income to the same extent as in a participating owner's individual Washington base income.source | The entity files its election by DOR's due date and no later than June 15 of the taxable year, makes estimated payments as individuals do (not required before July 1, 2029) and files an annual return.source | Imposed beginning January 1, 2028 (2026 c 238 s 502); no estimated payments required before July 1, 2029; 2026 c 238 s 1202 makes sections 1-1003 and 1201-1209 null and void if a court of final jurisdiction invalidates section 201.source | No holding or passive-entity carve-out from the pass-through entity tax was located, so no limits of such a carve-out are stated.source |
| WI 1/4 | Corporation includes an LLC treated as a corporation under the Internal Revenue Code.source | Apportionable income expressly includes intangible royalties, securities redemptions, specified interest and dividends, intangible sales, and partnership or LLC income shares.source | Interest, dividends, and intangible-sale income is apportionable under the quoted unitary operations or integral investment-activity conditions.source | The income tax reaches a corporation not subject to the franchise tax that owns Wisconsin property or has Wisconsin-source or attributable income.source | The listed holding-income categories are presumed apportionable when the statutory unitary or integral-investment conditions are met.source | A nonexempt corporation files by its federal return due date, without extension, and reports each item of nontaxable income.source | Current § 71.23(1) applies with the 7.9% rate stated in Wis. Stat. § 71.27(1).source | A federally disregarded single-owner entity is not a separate corporation under this chapter; its owner is subject to tax on or measured by the entity's income.source |
| WI 2/4 | Corporation includes an LLC treated as a corporation under the Internal Revenue Code.source | Apportionable income expressly includes intangible royalties, securities redemptions, specified interest and dividends, intangible sales, and partnership or LLC income shares.source | Interest, dividends, and intangible-sale income is apportionable under the quoted unitary operations or integral investment-activity conditions.source | The annual franchise tax reaches every nonexempt domestic or foreign corporation exercising its franchise or doing business in Wisconsin and is measured by Wisconsin net income.source | The listed holding-income categories are presumed apportionable when the statutory unitary or integral-investment conditions are met.source | A nonexempt corporation files by its federal return due date, without extension, and reports each item of nontaxable income.source | Current § 71.23(2) applies with the 7.9% rate stated in Wis. Stat. § 71.27(2).source | A federally disregarded single-owner entity is not a separate corporation under this chapter; its owner is subject to tax on or measured by the entity's income.source |
| WI 3/4 | Partnership includes a partnership-classified LLC; the corporate branch includes a corporate-classified LLC that is a federal S corporation.source | No holding-activity or passive-income carve-out was located in the complete partnership and S-corporation election subsections.source | No operative holding-entity or passive-income qualifying test was located in §§ 71.21(6) and 71.365(4m).source | An eligible partnership or federal S corporation may elect annual entity-level tax at 7.9% of Wisconsin-reportable net income.source | No holding-entity or passive-income carve-out was located in either election subsection; the regime is elective.source | The entity elects on or before its return's due date or extended due date; a partnership's general return rule is in § 71.20(1).source | Each current statutory election applies for the taxable year identified on the entity's timely or timely extended return.source | Election requires consent from holders of more than 50% of partnership capital and profits or more than 50% of corporation shares.source |
| WI 4/4 | The surcharge covers chapter 71 corporate and tax-option-corporation filers; corporation includes a federally corporate-classified LLC.source | The $4 million threshold uses gross receipts from all activities; the statute states no holding-activity category.source | A corporation must be required to file under chapter 71 subchapter IV or V and have at least $4 million in gross receipts from all activities.source | For the privilege of doing business, the surcharge applies to a corporation required to file under chapter 71 with at least $4 million in gross receipts.source | A qualifying corporation is subject based on gross receipts from all activities; § 77.93 states no special holding-entity treatment.source | A subject person files an accurate gross-tax-liability statement by the chapter 71 filing deadline, including extensions.source | The surcharge uses the same taxable year as the entity's chapter 71 tax and is due on the chapter 71 return due date without extension.source | The rule excludes an exempt corporation with no reportable unrelated business income; a federally disregarded single-owner entity is not separate under this subchapter.source |
| WV 1/2 | Article 24 includes an association or other organization taxable as a corporation under federal income-tax law within the corporation definition.source | No holding- or passive-activity carve-out was located in the complete corporation net income tax article.source | The complete corporation net income tax article states no separate qualifying test for a holding or passive entity.source | West Virginia imposes corporation net income tax on the West Virginia taxable income of every domestic or foreign corporation within the stated nexus, except §11-24-5 corporations.source | The generally applicable corporation net income tax applies; no holding-entity carve-out was located in the complete article.source | For tax years beginning after 2015, every corporation subject to Article 24 must file its return by the fifteenth day of the fourth month after the taxable year closes.source | The current corporation net income-tax paragraph applies to taxable periods beginning on or after January 1, 2014.source | No special statutory limit for holding or passive entities was located in the complete corporation net income tax article.source |
| WV 2/2 | Section 11-21-3a covers a partnership or other business entity not subject to Article 24; Article 10's person definition expressly includes an LLC or other pass-through entity.source | No holding- or passive-activity carve-out was located in the complete elective pass-through entity tax section, §11-21-3a.source | The complete elective-tax section states no separate qualifying test for a holding or passive entity.source | West Virginia annually imposes tax at the top individual marginal rate on the West Virginia taxable income of an electing pass-through entity.source | The statute defines income through owners' distributive shares and the resident owner's non-West-Virginia share; no holding-entity carve-out was located in the complete section.source | The entity must make its annual election on or before the return due date, including granted extensions; the election applies only to that taxable year and is irrevocable for that year.source | The entity-level election is available for taxable years beginning on and after January 1, 2022.source | The election is unavailable to a federally disregarded entity, and the pass-through entity definition excludes an entity subject to Article 24 corporation tax.source |
| WY 1/1 | Covers every LLC organized under Wyoming law and every foreign LLC that obtains a certificate of authority to transact and carry on business in Wyoming.source | No holding, passive-investment or intangible-income carve-out from the LLC annual license fee was located in the LLC Act or the Secretary of State's license tax rules and worksheet.source | No qualifying test exists to quote: no holding or passive-entity carve-out from the LLC annual license fee was located in the LLC Act or the Secretary of State's rules and worksheet.source | Every Wyoming LLC and every foreign LLC with a certificate of authority pays the Secretary of State an annual license fee with its annual report, based on capital, property and assets reported.source | The fee section reaches every domestic and authorized foreign LLC with no holding or passive-entity carve-out; its stated modifications cover interstate carriers, mine valuation and assessed value only.source | Every domestic LLC and authorized foreign LLC files an annual certification of capital, property and assets located and employed in Wyoming by the first day of its organization month.source | W.S. 17-29-1103 applies the LLC Act, which holds the fee, to domestic LLCs existing on July 1, 2010; the SoS fee schedule stating the license tax is effective July 1, 2026; no sunset text was located.source | No holding or passive-entity carve-out from the LLC annual license fee was located, so no limits of such a carve-out are stated.source |
Source: 142 regimes across 51 jurisdictions. Each source link opens the authority for its cell. The page source record lists the capture date and snapshot for every cell.
Field definitions
- Covered entity types
- The entity types the cited jurisdiction and regime variant places within the stated rule scope.
- Qualifying activities
- The activities or conditions the cited rule identifies for the named jurisdiction and regime variant.
- Qualifying test
- The source-bound test language recorded for the named jurisdiction and regime variant.
- Tax regime
- The named state regime represented by the cited jurisdiction and variant record.
- Treatment
- The treatment the cited source states for the named jurisdiction and regime variant.
- Filing rule
- The filing obligation stated for the named jurisdiction and regime variant, not a record-retention period.
- Effective period
- The effective period recorded for the cited jurisdiction and regime variant.
- Stated non-reach
- The limit or non-reach statement recorded for the named jurisdiction and regime variant.
Where to compare entity owner capacity by state
The Entity Owner Capacity by State reference compares the named role, assignment, and admission predicates across U.S. jurisdictions.
Use that state-law reference for corporation-director, limited-partnership general-partner, LLC manager, LLC member, assignment and admission, and trust-as-member questions. The reference does not establish federal tax classification, state holding-tax treatment, asset location, asset protection, net worth, available cash, solvency, or financial independence.
What the cited systems retain
Retention is not measured by this dataset.
A filing rule is an obligation field, not a retention field. It may state that a return, report, election, or other submission is required under the cited rule, but it does not state how long a taxing authority, registry, or another system keeps the submitted record. The three cell families on this page contain no field that measures that duration.
The same boundary applies to federal classification and state capacity. A classification source can establish its named treatment or constraint without measuring the storage life of an election, form, or agency record. A capacity source can establish a role or admission predicate without measuring how long a taxing authority or registry keeps a related submitted record.
No retention period is inferred from words such as filed, reported, effective, public, or required. Access, obligation, effective period, and record retention are separate predicates. A statement about one cannot supply the missing value for another. The Source Registry provides the source and correction route for retention facts outside the cited records.
What structure and classification records do not verify
These records do not establish net worth, available cash, solvency, beneficial economics, asset-protection results, or financial independence.
A federal classification cell states its cited legal or regulatory predicate. A state holding-entity cell states its cited scope, test, treatment, obligation, period, or limit. An entity-capacity cell states its cited role or admission predicate. None of those fields establishes net worth, available cash, solvency, beneficial economics, or financial independence for a particular operator or entity.
The number of entities in a structure is not an economic measure. More layers do not establish financial independence. A classification label also does not establish net worth, available cash, solvency, or beneficial economics. Those conclusions require evidence outside the cell families used here.
Financial independence is therefore a limit of this page, not a value derived from the tables. The page can show which rule question should be checked and which jurisdiction, entity type, field, variant, and date bound the answer. The cited rule records do not answer the separate economic question.
Asset location and asset protection remain separate. A classification or role may describe an entity or actor, while asset location asks where or through what vehicle an asset is held. Asset protection asks what cited remedy or disclosure rule applies. A title or location field cannot be rewritten as a protection result, and a capacity field cannot answer either question.
State tax treatment is likewise not a statement about a lower total liability or beneficial economics. A regime may impose, permit, define, or exclude something within its stated scope without establishing the operator's total liability or result. This page maps the rules and their limits; it does not transform them into an outcome claim.
How to read scope, dates, and unknown fields
Each statement stays attached to its jurisdiction, entity type, field, variant, source date, and displayed unknown boundary; no other row fills it.
Jurisdiction is part of every statement. The federal cells answer only the US-federal classification questions named by their fields and variants. A state holding-entity row answers only for its jurisdiction and named regime variant. A capacity row answers only for its jurisdiction, entity type, and role or admission field. A statement should not be carried across those boundaries because the wording appears similar.
Variant is also part of the fact. The state holding-entity family contains multiple named regimes in some jurisdictions. Covered entities, qualifying activities, tests, treatment, filing rules, effective periods, and non-reach statements travel as one variant-specific set. Combining one variant's test with another variant's treatment would create a rule no cell states.
Dates report when the source was checked or the rule period recorded. They do not promise that a statute, regulation, instruction, filing requirement, or administrative page has remained unchanged. A correction must identify the exact jurisdiction, entity type, field, variant, source, and date that changed before the displayed statement changes.
An Unknown badge marks a bounded evidence gap. It does not mean no rule exists, the opposite answer is true, another entity type follows the same rule, or another jurisdiction supplies the missing value. The visible explanation remains with the affected cell. The rest of the row does not cure that missing field, and the gap cannot be softened into a general statement.
The parent operator finance and independence hub connects this rule map to its sibling tasks. FIRE vs. operator liquidity keeps rule constraints separate from available cash, while the asset-location sibling keeps title and vehicle evidence separate from remedy evidence. Those links provide context without changing a cell's scope.
How to read Unknown
- Unknown: Verified absence
- The captured authority was searched and shows no such rule or filing. No value is printed because the absence is the finding. The reason and the authority are printed beside the badge.
- Unknown: Checked — record silent
- The official source for this field was read, and its own text is silent on it. No value is printed and none is inferred from the silence. The note beside the badge is either a line saying the record does not state it or the passage of the record that was read; the authority is linked.
- Unknown: Not yet verified
- The captured sources did not settle this field yet. No value is printed, not even an earlier one. The reason is printed beside the badge, and an authority is linked only when one was supplied.