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      "source_sha256": "68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7",
      "source_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AK.llc.tax_regime.personal_holding_company_tax": {
      "additional_sources": [
        {
          "pinpoint": "AS 43.20.021(b)",
          "quote": "For purposes of calculating the federal tax payable on personal holding companies provided for in the provisions of 26 U.S.C. 541 (Internal Revenue Code), the rate is 12.6 percent.",
          "role": "statutory_rate_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/AK/snapshots/c50/title-43.pdf/AK/68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7.pdf",
          "source_sha256": "68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7",
          "source_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "Alaska assesses a personal-holding-company tax in addition to ordinary corporation tax and uses the Alaska statutory rate.",
      "fetch_event_id": null,
      "pinpoint": "Form 6000 instructions, page 9, Schedule E line 4",
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      "publish_status": "publish_ready",
      "quote": "Line 4, Personal Holding Company (PHC) tax: Report the PHC tax of 12.6%, apportioned if appropriate. This tax is assessed in addition to tax calculated at ordinary tax rates on Schedule D.",
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      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AK/c28ebb5f69d64f10bcbf706993846d680fe42f8dcf13ce75ef2ba584b569d78f.pdf",
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      "source_class": "S1",
      "source_sha256": "c28ebb5f69d64f10bcbf706993846d680fe42f8dcf13ce75ef2ba584b569d78f",
      "source_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AK.llc.tax_regime.s_corporation_excess_net_passive_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "26 U.S.C. § 1375(a)",
          "quote": "If for the taxable year an S corporation has— (1) accumulated earnings and profits at the close of such taxable year, and (2) gross receipts more than 25 percent of which are passive investment income, then there is hereby imposed a tax on the income of such corporation for such taxable year. Such tax shall be computed by multiplying the excess net passive income by the highest rate of tax specified in section 11(b).",
          "role": "incorporated_imposition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/AK/snapshots/c50/irc-1375-govinfo.html/AK/b16dac79bef1abdedc390433ad8035774c6b5b486dffa524cb651c684026ecb3.html",
          "source_sha256": "b16dac79bef1abdedc390433ad8035774c6b5b486dffa524cb651c684026ecb3",
          "source_url": "https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapS-partIII-sec1375.htm"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "Alaska imposes the incorporated excess-net-passive-income tax on an S corporation at the stated Alaska marginal rate.",
      "fetch_event_id": null,
      "pinpoint": "Form 6000 instructions, page 3, Sub-Chapter S Corporation",
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      "publish_status": "publish_ready",
      "quote": "Alaska imposes both the federal excess net passive income tax and the corporate-level tax on built-in gains. These taxes are calculated at the highest Alaska marginal tax rate of 9.4%. If corporate-level taxes are imposed, attach copies of the schedules and forms calculating the federal tax and the Alaska tax. Enter the corporate-level taxes on Form 6000, Schedule E, line 6.",
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      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AK/c28ebb5f69d64f10bcbf706993846d680fe42f8dcf13ce75ef2ba584b569d78f.pdf",
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      "source_class": "S1",
      "source_sha256": "c28ebb5f69d64f10bcbf706993846d680fe42f8dcf13ce75ef2ba584b569d78f",
      "source_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AK.llc.tax_regime.state_business_license_fee": {
      "additional_sources": [
        {
          "pinpoint": "AS 43.70.030(a)",
          "quote": "The fee for each business license is $50 a year, except that the fee is $25 if the business is a sole proprietorship",
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          "snapshot_path": "rigs/entity-research/holding-tax/discovery/AK/snapshots/c50/title-43.pdf/AK/68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7.pdf",
          "source_sha256": "68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A person engaging in business in Alaska must first obtain a business license and pay the statutory annual fee.",
      "fetch_event_id": null,
      "pinpoint": "AS 43.70.020(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For the privilege of engaging in a business in the state, a person shall first apply, on forms prescribed by the commissioner, and obtain a license, and pay the license fee provided for in AS 43.70.030.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AK/snapshots/c50/title-43.pdf/AK/68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7",
      "source_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AK.llc.treatment.corporation_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Qualifying foreign-corporation dividends and royalties receive statutory exclusions from taxable income; Chapter 20 states no general holding-entity exemption.",
      "fetch_event_id": null,
      "pinpoint": "AS 43.20.145(b)-(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "When computing taxable income for a corporation under (a) of this section, the following amounts shall be excluded: (1) 80 percent of dividend income received from foreign corporations; (2) an amount treated as a dividend under 26 U.S.C. 78; (3) 80 percent of the royalties accrued or received from a foreign corporation. […] In (b)(1) and (3) of this section, a payment is considered to be received from a corporation that is part of the unitary business if the payment is received (1) by a member of an affiliated group included in a water's edge combined report filed under this section; and (2) from a corporation in which the recipient owns 50 percent or more of the stock of the corporation.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AK/snapshots/c50/title-43.pdf/AK/68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AK.llc.treatment.personal_holding_company_tax": {
      "additional_sources": [
        {
          "pinpoint": "AS 43.20.021(b)",
          "quote": "For purposes of calculating the federal tax payable on personal holding companies provided for in the provisions of 26 U.S.C. 541 (Internal Revenue Code), the rate is 12.6 percent.",
          "role": "statutory_rate_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/AK/snapshots/c50/title-43.pdf/AK/68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7.pdf",
          "source_sha256": "68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7",
          "source_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "A qualifying personal holding company calculates ordinary Alaska corporation tax and a separate add-on reported on Schedule E.",
      "fetch_event_id": null,
      "pinpoint": "Form 6000 instructions, page 9, Schedule D and Schedule E line 4",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Line 4, Personal Holding Company (PHC) tax: Report the PHC tax of 12.6%, apportioned if appropriate. This tax is assessed in addition to tax calculated at ordinary tax rates on Schedule D.",
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      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AK/c28ebb5f69d64f10bcbf706993846d680fe42f8dcf13ce75ef2ba584b569d78f.pdf",
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      "source_class": "S1",
      "source_sha256": "c28ebb5f69d64f10bcbf706993846d680fe42f8dcf13ce75ef2ba584b569d78f",
      "source_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AK.llc.treatment.s_corporation_excess_net_passive_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "26 U.S.C. § 1375(a)",
          "quote": "If for the taxable year an S corporation has— (1) accumulated earnings and profits at the close of such taxable year, and (2) gross receipts more than 25 percent of which are passive investment income, then there is hereby imposed a tax on the income of such corporation for such taxable year. Such tax shall be computed by multiplying the excess net passive income by the highest rate of tax specified in section 11(b).",
          "role": "incorporated_base_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/AK/snapshots/c50/irc-1375-govinfo.html/AK/b16dac79bef1abdedc390433ad8035774c6b5b486dffa524cb651c684026ecb3.html",
          "source_sha256": "b16dac79bef1abdedc390433ad8035774c6b5b486dffa524cb651c684026ecb3",
          "source_url": "https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapS-partIII-sec1375.htm"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "Although ordinary pass-through items are not taxed to the S corporation, Alaska separately taxes excess net passive income at the stated corporate rate.",
      "fetch_event_id": null,
      "pinpoint": "Form 6000 instructions, page 3, Sub-Chapter S Corporation",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Alaska imposes both the federal excess net passive income tax and the corporate-level tax on built-in gains. These taxes are calculated at the highest Alaska marginal tax rate of 9.4%. If corporate-level taxes are imposed, attach copies of the schedules and forms calculating the federal tax and the Alaska tax. Enter the corporate-level taxes on Form 6000, Schedule E, line 6.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AK/c28ebb5f69d64f10bcbf706993846d680fe42f8dcf13ce75ef2ba584b569d78f.pdf",
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      "source_class": "S1",
      "source_sha256": "c28ebb5f69d64f10bcbf706993846d680fe42f8dcf13ce75ef2ba584b569d78f",
      "source_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AK.llc.treatment.state_business_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The license-fee statute reaches a person engaging in statutory business, and complete Chapter 70 contains no general holding- or passive-entity carve-out.",
      "fetch_event_id": null,
      "pinpoint": "AS 43.70.020(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For the privilege of engaging in a business in the state, a person shall first apply, on forms prescribed by the commissioner, and obtain a license, and pay the license fee provided for in AS 43.70.030.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AK/snapshots/c50/title-43.pdf/AK/68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "68c909776a9e546c43408fee748dd2fe9aaeed1aea1b8f8bd3fc9f34d7df1ba7",
      "source_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
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    "holding_tax:pp-holding-entity-tax#AL.llc.base_tax_locator.business_privilege_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The Business Privilege Tax rate, minimum, and maximum provisions are located in Ala. Code § 40-14A-22(b)-(d).",
      "fetch_event_id": null,
      "pinpoint": "Ala. Code § 40-14A-22(b)-(d)",
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      "publish_status": "publish_ready",
      "quote": "(b) Rate of tax. For all taxable years of taxpayers that begin after December 31, 1999, the rate of tax shall be as set forth below. If taxable income of the taxpayer is: at least but less than The tax rate shall be $1 $0.25 per $1,000 $1 $200,000 $1.00 per $1,000 $200,000 $500,000 $1.25 per $1,000 $500,000 $2,500,000 $1.50 per $1,000 $2,500,000 $1.75 per $1,000 (c) Minimum tax. (1) Except as provided in subsection (f), and subdivisions (2) and (3), the privilege tax levied by this article on certain corporations, business trusts, limited liability entities, and disregarded entities shall not be less than $100. (2) For the taxable year beginning after December 31, 2022, taxpayers who would otherwise be subject to the minimum tax due of $100 provided for in subdivision (c)(1) shall pay $50 in lieu thereof. This subdivision shall not apply to those subject to the tax levy provided under Section 20-2A-80. (3) For taxable years beginning after December 31, 2023, taxpayers who would otherwise be subject to the minimum tax due provided for in subdivisions (c)(1) or (c)(2) shall be exempt from the privilege tax levied by this article and the associated filing requirement. This subdivision shall not apply to those subject to the tax levy provided under Section 20-2A-80. (d) Maximum tax. (1) Except as provided in subdivision (2), the privilege tax levied by this article shall not exceed $15,250 for any taxpayer for the taxable year beginning January 1, 2000. For each taxable year thereafter, the maximum tax shall not exceed $15,000 for any taxpayer, except as provided in subdivision (2). (2) With respect to any (i) financial institution groups as defined in subsection (f)(1); (ii) insurance company that is subject to the premium taxes levied by Chapter 4A of Title 27; and (iii) corporation, company, limited liability entity, or association whose property is assessed for taxation pursuant to the provisions of Chapter 21 and is obligated to serve the general public, but is not subject to the Alabama Corporate Income tax, the privilege tax levied by this article shall not exceed $3,000,000, for any taxpayer or, for a financial institution group, for the financial institution group as a whole each year except as provided in subsection (e). The privilege tax levied by this article on any electing family limited liability entity shall not exceed $500.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AL/snapshots/c50/AL/0197eb42777c4d4bcd31f4edd6b55d46718c94def4974b157abdc02b428f5abf.json",
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      "source_sha256": "0197eb42777c4d4bcd31f4edd6b55d46718c94def4974b157abdc02b428f5abf",
      "source_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
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    "holding_tax:pp-holding-entity-tax#AL.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate-income tax rate is located in Ala. Code § 40-18-31(a), and the taxable-income base is located in § 40-18-33.",
      "fetch_event_id": null,
      "pinpoint": "Ala. Code §§ 40-18-31(a), 40-18-33",
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      "quote": "(a) A corporation subject to the tax imposed by Section 40-18-2 shall pay a tax equal to six and one-half percent of the taxable income of the corporation, as defined in this chapter. […] In the case of a corporation subject to the tax imposed by Section 40-18-31, the term “taxable income” means federal taxable income without the benefit of federal net operating losses plus the additions prescribed and less the deductions and adjustments allowed by this chapter and as allocated and apportioned to Alabama.",
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      "source_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
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    "holding_tax:pp-holding-entity-tax#AL.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective pass-through-entity tax rate, calculation, and apportionment locators are stated in Ala. Code § 40-18-24.4(e).",
      "fetch_event_id": null,
      "pinpoint": "Ala. Code § 40-18-24.4(e)",
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      "quote": "(e) An electing pass-through entity shall pay a tax at the highest marginal rate provided in Section 40-18-5, calculated in accordance with Section 40-18-24 or Section 40-18-161 and Section 40-18-162, as appropriate, and apportioned in accordance with Chapter 27. An electing pass-through entity shall be subject to Section 40-18-80.1 (estimated tax for corporations). In calculating taxable income for the purposes of this subsection, Alabama tax paid under this subsection shall not be deducted in calculating Alabama taxable income.",
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      "source_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
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    "holding_tax:pp-holding-entity-tax#AL.llc.does_not_reach.business_privilege_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Ala. Code §§ 40-14A-1(k), 40-14A-22(d)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(k) LIMITED LIABILITY ENTITY. Any entity, other than a corporation, organized under the laws of this or any other jurisdiction through which business may be conducted while offering limited liability to the owners of the entity with respect to some or all of the obligations of the entity and which is taxable under subchapter K of the Code, including, without limitation, limited liability companies, registered limited liability partnerships, and limited partnerships. […] The privilege tax levied by this article on any corporation organized as a not-for-profit corporation that does not engage in any business other than holding title to property and paying the expenses thereof, including, without limitation, a property owners’ association or a corporation organized solely to hold title to property on a temporary basis, shall not exceed $100.",
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      "source_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AL.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "Ala. Code § 40-18-35(a)(7)",
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      "publish_status": "publish_ready",
      "quote": "(7) If the taxpayer owns greater than 20 percent of the stock, by vote or value, of the distributing corporation the following deductions are allowed: a. Amounts described in 26 U.S.C. § 78; b. Dividend income, including amounts described in 26 U.S.C. § 951, from non-U.S. corporations to the same extent such dividend income would be deductible under 26 U.S.C. § 243 if received from U.S. corporations; and c. Dividends received from foreign sales corporations as defined in 26 U.S.C. § 922. d. Dividend income from a Captive REIT to the same extent such dividend income would be deductible under 26 U.S.C. § 243 if received from an entity that is not a REIT.",
      "readiness": "ready",
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      "display": "The elective pass-through-entity tax election is available for tax years beginning on or after January 1, 2021.",
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      "quote": "(a) Every taxpayer shall file a privilege tax return, which shall include the public record disclosures required by Section 10-2B-16.22, with the department for every taxable year for which it is subject to the tax levied by this article.",
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      "display": "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.",
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      "quote": "(a) Except as provided in subsection (c), every corporation, joint stock company, or association subject to income tax under this chapter shall file a return with the Department of Revenue for each taxable year, stating specifically the items of its gross income and the deductions and credits allowed by this chapter.",
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      "display": "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.",
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      "quote": "(a) Levy of tax. There is hereby levied an annual privilege tax on every corporation, limited liability entity, and disregarded entity doing business in Alabama, or organized, incorporated, qualified, or registered under the laws of Alabama. The tax shall accrue as of January 1 of every taxable year, or in the case of a taxpayer organized, incorporated, qualified, or registered during the year, or doing business in Alabama for the first time, as of the date the taxpayer is organized, incorporated, registered, or qualifies to do business, or begins to do business in Alabama, as the case may be. The taxpayer shall be liable for the tax levied by this article for each year beginning before the taxpayer has been dissolved or otherwise ceased to exist or has withdrawn or forfeited its qualification to do business in Alabama. The amount of the tax due shall be determined by multiplying the taxpayer’s net worth in Alabama by the rate determined in subsection (b).",
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        {
          "pinpoint": "Ala. Code § 40-18-1(8)",
          "quote": "(8) CORPORATION. The term includes associations, joint stock companies, and any other entity classified as an association taxable as a corporation for federal income tax purposes.",
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      "display": "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.",
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          "pinpoint": "Ala. Code § 40-18-24.4(b)-(c)",
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      "quote": "(e) An electing pass-through entity shall pay a tax at the highest marginal rate provided in Section 40-18-5, calculated in accordance with Section 40-18-24 or Section 40-18-161 and Section 40-18-162, as appropriate, and apportioned in accordance with Chapter 27. An electing pass-through entity shall be subject to Section 40-18-80.1 (estimated tax for corporations). In calculating taxable income for the purposes of this subsection, Alabama tax paid under this subsection shall not be deducted in calculating Alabama taxable income.",
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      "claim_type": "primary",
      "display": "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.",
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      "pinpoint": "Ala. Code § 40-18-35(a)(7)",
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      "quote": "(7) If the taxpayer owns greater than 20 percent of the stock, by vote or value, of the distributing corporation the following deductions are allowed: a. Amounts described in 26 U.S.C. § 78; b. Dividend income, including amounts described in 26 U.S.C. § 951, from non-U.S. corporations to the same extent such dividend income would be deductible under 26 U.S.C. § 243 if received from U.S. corporations; and c. Dividends received from foreign sales corporations as defined in 26 U.S.C. § 922. d. Dividend income from a Captive REIT to the same extent such dividend income would be deductible under 26 U.S.C. § 243 if received from an entity that is not a REIT.",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The LLC minimum-franchise-tax rule is located at Ark. Code Ann. § 26-54-104(8).",
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      "pinpoint": "Act 459 of 2023, § 5; Ark. Code Ann. § 26-54-104(8)",
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      "quote": "(8) An organization formed pursuant to the Uniform Limited Liability Company Act, § 4-38-101 et seq., shall pay the minimum franchise tax.",
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      "capture_date": "2026-10-03",
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      "display": "The domestic corporate-income-tax rate schedule is located at Ark. Code Ann. § 26-51-205(a)(5), as amended by Act 4 of 2024, § 2.",
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      "quote": "SECTION 2. Arkansas Code § 26-51-205(a)(5), concerning the income tax 06/14/2024 8:51:08 AM JLL435 imposed on domestic corporations, is amended to read as follows: (5) For tax years beginning on or after January 1, 2024, every corporation organized under the laws of this state shall pay annually an income tax with respect to carrying on or doing business on the entire net income of the corporation, as now defined by the laws of this state, received by the corporation during the income year, on the following basis: (A) income or any part thereof, one percent (1%); (B) On the next three thousand dollars ($3,000) of net income or any part thereof, two percent (2%); On the first three thousand dollars ($3,000) of net (C) On the next five thousand dollars ($5,000) of net income or any part thereof, three percent (3%); and (D) On net income exceeding eleven thousand dollars ($11,000), four and eight-tenths percent (4.8%) four and three-tenths percent (4.3%).",
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      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The ordinary PTE rate and the net-capital-gain half-rate rule are located at Ark. Code Ann. § 26-65-103(b)(1).",
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      "quote": "Before the fifteenth day of the fourth month of the taxable year, an affected business entity shall pay to the Secretary of the Department of Finance and Administration the tax determined under this section. (b)(1)(A) Except as provided in subdivision (b)(1) […] (B) For an affected business entity that has a net capital gain, the rate of tax on the capital gain shall be fifty percent (50%) of the rate specified in subdivision (b)(1)(A) of this section.",
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      "capture_date": "2026-10-03",
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      "display": "The computation rate and transfer to Form AR1100PET are located at line 11 of the excess-net-passive-income worksheet.",
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      "pinpoint": "2025 AR1100PET Instructions, excess-net-passive-income worksheet, line 11",
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      "quote": "Excess Net Passive Income Tax Worksheet 1. Enter Arkansas gross receipts for the tax year (See IRC Section 1362 (d)(3)(B) for gross receipts from the sale of capital assets.)* ..................................................... 2. Enter Arkansas passive investment income as defined in IRC* Section 1362 (d)(3)(C) ... 3. Enter 25% of Line 1 (If Line 2 is less than Line 3, stop here. You are not liable for this tax.) ............................................................ 4. Excess Arkansas passive investment income (Subtract Line 3 from Line 2.) ......... 5. Arkansas expenses directly connected with the production of income on Line 2 [See IRC* Section 1375(b)(2)] .................... 6. Net passive income (Subtract Line 5 from Line 2.) ............................................... 7. Divide amount on Line 4 by amount on Line 2. ................................................... 8. Excess net passive income (Multiply Line 6 by Line 7.) ........................................ 9. Enter taxable income (See instructions for taxable income below.) .......................... 10. Enter the smaller of Line 8 or 9 ................... 11. Excess net passive income tax: Enter 4.3% of Line 10. Enter here and on Line 6, P1, Form AR1100PET.................................",
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    "holding_tax:pp-holding-entity-tax#AR.llc.does_not_reach.annual_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current LLC report identifies only nonprofit/federally income-tax-exempt corporations and Uniform Partnership or Limited Partnership Act organizations as exempt.",
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      "pinpoint": "2026 Arkansas Annual LLC Franchise Tax Report, Who Files",
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      "quote": "WHO FILES ANNUAL FRANCHISE TAX REPORTS: All domestic and foreign corporations, associations, organizations, and companies constituting a separate legal entity of relationship with the purpose of obtaining a privilege or franchise which is not allowed to them as individuals except those exempted by A.C.A. § 26-54-102. The only exemptions are nonprofit corporations, which are organizations exempt from the federal income tax, or organizations formed pursuant to the Uniform Partnership Act, A.C.A. § 4-46-101 et seq., or the Uniform Limited Partnership Act, A.C.A. § 4-47-101 et seq. 1. 2.",
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      "source_url": "https://www.sos.arkansas.gov/uploads/bcs/LLC1_FT_2026.pdf",
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    "holding_tax:pp-holding-entity-tax#AR.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The exemption is limited to qualifying dividends; the instructions separately require taxable interest, gross rents, and gross royalties to be entered.",
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      "pinpoint": "2025 Corporation Income Tax Instructions, lines 4-7",
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      "quote": "Line 4 - Dividends: Enter taxable dividends only. Dividends from 80% or greater directly owned subsidiaries are exempt. Line 5 - Taxable Interest: Enter interest income taxable in Arkansas. Enter amounts received or credited as interest to the corporation during the tax year on bank deposits, C.D.’s, notes, mortgages, corporation bonds, taxable U.S. interest, and all other interest including interest on out-of-state municipal bonds (out-of-state municipal bonds are taxable in Arkansas). Attach schedule to the Arkansas return identifying each U.S. Agency or political subdivision of Arkansas and Schedule AR1100REC to reconcile amounts received that are not included as taxable interest on the Arkansas return. Line 6 - Gross Rents: Enter all gross rents. Attach detailed schedule showing amounts received if now shown separately on the federal return. The schedule should reconcile Arkansas and federal rents. Line 7 - Gross Royalties: Enter all gross royalties. Attach detailed schedule showing amounts received if now shown separately on the federal return. The schedule should reconcile Arkansas and federal royalties.",
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      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/CorporationIncomeTaxInstructions_2025.pdf",
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      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The half-rate treatment is confined to net capital gain; the main levy applies to the affected entity's net taxable business income.",
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      "pinpoint": "Act 362 of 2021, § 2; Ark. Code Ann. § 26-65-103(a), (b)(1)",
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      "quote": "Before the fifteenth day of the fourth month of the taxable year, an affected business entity shall pay to the Secretary of the Department of Finance and Administration the tax determined under this section. (b)(1)(A) Except as provided in subdivision (b)(1) […] (B) For an affected business entity that has a net capital gain, the rate of tax on the capital gain shall be fifty percent (50%) of the rate specified in subdivision (b)(1)(A) of this section.",
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      "capture_date": "2026-10-03",
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      "display": "The line does not apply if the corporation has always been a Subchapter S corporation; the instructions also require all three listed liability conditions.",
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      "quote": "Line 6 - Excess Net Passive Income Tax S Corporations are subject to Arkansas income tax on excess net passive income in the same manner that such items are taxed federally. Enter the tax on Line 6 of AR1100PET and attach a schedule showing the computation of the tax. Enter the excess net passive income tax due. If the corporation has always been a Subchapter S corporation, P1 Line 6 tax does not apply. If the corporation has Ccorporation earnings and profits at year-end, passive investment income exceeding 25% of gross receipts, and taxable income, determine liability using the worksheet (complete lines 1–3 and 9); if line 2 exceeds line 3, the tax applies. Compute the tax on a separate schedule using the worksheet format (lines 1–11). The 2024 rate is 4.3%.",
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      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current form is the 2026 annual LLC franchise-tax report and states a May 1, 2026 due date.",
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      "pinpoint": "2026 Arkansas Annual LLC Franchise Tax Report, first page",
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      "quote": "Reports and taxes are due on or before May 1, 2026. Penalty and interest will be due for reports if the United States Postal Service’s postmark is after the deadline.",
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      "source_url": "https://www.sos.arkansas.gov/uploads/bcs/LLC1_FT_2026.pdf",
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      "capture_date": "2026-10-03",
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      "display": "The current domestic-corporation provision applies to tax years beginning on or after January 1, 2024.",
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      "pinpoint": "Act 4 of 2024 (Second Extraordinary Session), § 2; Ark. Code Ann. § 26-51-205(a)(5)",
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      "quote": "For tax years beginning on or after January 1, 2024, every corporation organized under the laws of this state shall pay annually an income tax with respect to carrying on or doing business on the entire net income of the corporation, as now defined by the laws of this state, received by the corporation during the income year,",
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      "display": "Act 362's elective PTE provisions apply to tax years beginning on or after January 1, 2022.",
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      "quote": "EFFECTIVE DATE. Sections 1 and 2 of this act are effective for tax years beginning on or after January 1, 2022.",
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      "capture_date": "2026-10-03",
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      "display": "The 2025 instructions identify 4.3% as the 2024 rate for this line-6 tax.",
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      "quote": "The 2024 rate is 4.3%.",
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      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "LLCs may file through the Secretary of State website or on paper, and all companies must comply with the May 1 due date.",
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      "pinpoint": "2026 Arkansas Annual LLC Franchise Tax Report, Responsibility",
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      "publish_status": "publish_ready",
      "quote": "RESPONSIBILITY: Companies not receiving a form by March 20 must make a written request for paper forms. Fillable PDF forms can be downloaded, or franchise taxes can be filed online, through the Secretary of State’s website at www.sos.arkansas.gov. All companies must comply with the May 1 due date. b)",
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      "source_url": "https://www.sos.arkansas.gov/uploads/bcs/LLC1_FT_2026.pdf",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
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      "display": "Arkansas corporate income-tax returns are due on the fifteenth day of the fourth month following the end of the tax year.",
      "fetch_event_id": null,
      "pinpoint": "2025 Corporation Income Tax Instructions, Time For Filing",
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      "publish_status": "publish_ready",
      "quote": "Time For Filing Arkansas adopted a new due date for Corporate Income tax returns for tax years beginning on or after January 1, 2016. Arkansas Corporate Income Tax Returns are now due the 15th day of the 4th month following the end of the tax year. This includes short tax years. Cooperative Association returns are due on or before the 15th day of the 9th month following the close of the tax year. Exempt organizations are due on the 15th day of the 5th month.",
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      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/CorporationIncomeTaxInstructions_2025.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AR.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "2025 AR1100PET Instructions, Time/Filing as a Pass-Through Entity",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The election to be subject to the PET tax must be made by owner members representing more than 50% of the voting power of the pass-through entity. The election is due before the due date for filing a return as extended. The election may be made by filing Form AR362‑E on paper or by registering in ATAP, or by filing a PET income tax return before the due date. DFA encourages taxpayers wishing to make estimated or extension payments before the filing of a return to file an election so that payments can more easily be associated with a specific taxpayer account. Form AR1100PET is due on or before the 15th day of the 4th month following the close of the entity’s tax year.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AR.llc.filing_rule.s_corporation_excess_net_passive_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Enter the tax on AR1100PET line 6 and attach a schedule showing the computation in the worksheet's line 1-11 format.",
      "fetch_event_id": null,
      "pinpoint": "2025 AR1100PET Instructions, line 6",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Line 6 - Excess Net Passive Income Tax S Corporations are subject to Arkansas income tax on excess net passive income in the same manner that such items are taxed federally. Enter the tax on Line 6 of AR1100PET and attach a schedule showing the computation of the tax. Enter the excess net passive income tax due. If the corporation has always been a Subchapter S corporation, P1 Line 6 tax does not apply. If the corporation has Ccorporation earnings and profits at year-end, passive investment income exceeding 25% of gross receipts, and taxable income, determine liability using the worksheet (complete lines 1–3 and 9); if line 2 exceeds line 3, the tax applies. Compute the tax on a separate schedule using the worksheet format (lines 1–11). The 2024 rate is 4.3%.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2",
      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AR.llc.tax_regime.annual_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Unless exempted under § 26-54-105, every entity within the chapter's corporation definition files an annual report and pays annual franchise tax.",
      "fetch_event_id": null,
      "pinpoint": "Act 459 of 2023, § 5; Ark. Code Ann. § 26-54-104(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Unless exempted under § 26-54-105, every corporation shall file an annual franchise tax report and pay an annual franchise tax as follows:",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/403a18f0d2a2d87a2ca62bb38c9438bf83541748d9953b898f9b91c5d1e4a572.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "403a18f0d2a2d87a2ca62bb38c9438bf83541748d9953b898f9b91c5d1e4a572",
      "source_url": "https://www.arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2023R%2FPublic%2FACT459.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AR.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Act 4 of 2024 (Second Extraordinary Session), § 2; Ark. Code Ann. § 26-51-205(a)(5)",
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      "publish_status": "publish_ready",
      "quote": "For tax years beginning on or after January 1, 2024, every corporation organized under the laws of this state shall pay annually an income tax with respect to carrying on or doing business on the entire net income of the corporation, as now defined by the laws of this state, received by the corporation during the income year,",
      "readiness": "ready",
      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/c6889390562416b633e5e3a90c386104a84b40774904c83e28aaaccfce8a8f05.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "c6889390562416b633e5e3a90c386104a84b40774904c83e28aaaccfce8a8f05",
      "source_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2024S2%2FPublic%2FACT4.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AR.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "2025 AR1100PET Instructions, What is the Pass-Through Entity Tax",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "What is the Pass-Through Entity Tax The Elective Pass-Through Entity Tax or PET Tax allows a partnership, Sub-S corporation or limited liability company to file a single income tax return on behalf of the entity and pay the income tax on behalf of all owner members. The PET tax is not available to C corporations, qualified subchapter S subsidiaries, trusts, sole proprietorships or limited liability companies taxed as C corporations for federal income tax purposes. The PET tax is effective for tax years beginning on or after January 1, 2022. The PET tax rate for all taxpayers will be the same for all owner members and will be equal to the highest income tax rate for individuals. The tax rate on capital gains will be one half of the rate of tax on other types of income of an entity subject to the PET tax. For tax years beginning in 2024, the tax rate on income other than capital gains will be 3.9% and the tax rate for capital gains will be 1.95%. The due date for the PET tax will be the same as other income taxes and will be April 15 for calendar year filers. The PET tax is subject to all provisions of the Arkansas Tax Procedure Act. All penalty and interest provisions, statute of limitation for refunds and assessments, and other provisions apply. The PET tax must be paid in quarterly installments if the tax exceeds $1,000 in order to avoid the penalty for underpayment of estimated taxes. Payments for estimated taxes, extension payments, return payments, etc., may be made by check or through the Arkansas Taxpayer Access Point (ATAP).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2",
      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AR.llc.tax_regime.s_corporation_excess_net_passive_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "2025 AR1100PET Instructions, line 6",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Line 6 - Excess Net Passive Income Tax S Corporations are subject to Arkansas income tax on excess net passive income in the same manner that such items are taxed federally. Enter the tax on Line 6 of AR1100PET and attach a schedule showing the computation of the tax. Enter the excess net passive income tax due. If the corporation has always been a Subchapter S corporation, P1 Line 6 tax does not apply. If the corporation has Ccorporation earnings and profits at year-end, passive investment income exceeding 25% of gross receipts, and taxable income, determine liability using the worksheet (complete lines 1–3 and 9); if line 2 exceeds line 3, the tax applies. Compute the tax on a separate schedule using the worksheet format (lines 1–11). The 2024 rate is 4.3%.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2",
      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AR.llc.treatment.annual_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "An LLC is taxed under the universal annual-franchise-tax rule and pays the minimum franchise tax; no separate holding-company treatment was located.",
      "fetch_event_id": null,
      "pinpoint": "Act 459 of 2023, § 5; Ark. Code Ann. § 26-54-104(a), (8)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Unless exempted under § 26-54-105, every corporation shall file an annual franchise tax report and pay an annual franchise tax as follows: […] (8) An organization formed pursuant to the Uniform Limited Liability Company Act, § 4-38-101 et seq., shall pay the minimum franchise tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/403a18f0d2a2d87a2ca62bb38c9438bf83541748d9953b898f9b91c5d1e4a572.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "403a18f0d2a2d87a2ca62bb38c9438bf83541748d9953b898f9b91c5d1e4a572",
      "source_url": "https://www.arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2023R%2FPublic%2FACT459.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AR.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A corporation-classified LLC remains in the corporate-income-tax regime, but dividends from an 80%-or-greater directly owned subsidiary are exempt.",
      "fetch_event_id": null,
      "pinpoint": "2025 Corporation Income Tax Instructions, line 4",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Line 4 - Dividends: Enter taxable dividends only. Dividends from 80% or greater directly owned subsidiaries are exempt.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/4fa9cf442214c90fa04d0c18968a1f49e43378b5d0a0ebc26431c78dbbdbb6b8.pdf",
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      "source_class": "S1",
      "source_sha256": "4fa9cf442214c90fa04d0c18968a1f49e43378b5d0a0ebc26431c78dbbdbb6b8",
      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/CorporationIncomeTaxInstructions_2025.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AR.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "2025 AR1100PET Instructions, PTE overview",
          "quote": "What is the Pass-Through Entity Tax The Elective Pass-Through Entity Tax or PET Tax allows a partnership, Sub-S corporation or limited liability company to file a single income tax return on behalf of the entity and pay the income tax on behalf of all owner members. The PET tax is not available to C corporations, qualified subchapter S subsidiaries, trusts, sole proprietorships or limited liability companies taxed as C corporations for federal income tax purposes. The PET tax is effective for tax years beginning on or after January 1, 2022. The PET tax rate for all taxpayers will be the same for all owner members and will be equal to the highest income tax rate for individuals. The tax rate on capital gains will be one half of the rate of tax on other types of income of an entity subject to the PET tax. For tax years beginning in 2024, the tax rate on income other than capital gains will be 3.9% and the tax rate for capital gains will be 1.95%. The due date for the PET tax will be the same as other income taxes and will be April 15 for calendar year filers. The PET tax is subject to all provisions of the Arkansas Tax Procedure Act. All penalty and interest provisions, statute of limitation for refunds and assessments, and other provisions apply. The PET tax must be paid in quarterly installments if the tax exceeds $1,000 in order to avoid the penalty for underpayment of estimated taxes. Payments for estimated taxes, extension payments, return payments, etc., may be made by check or through the Arkansas Taxpayer Access Point (ATAP).",
          "role": "current agency confirmation of half-rate treatment",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2.pdf",
          "source_sha256": "bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2",
          "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Act 362 of 2021, § 2; Ark. Code Ann. § 26-65-103(b)(1)(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(B) For an affected business entity that has a net capital gain, the rate of tax on the capital gain shall be fifty percent (50%) of the rate specified in subdivision (b)(1)(A) of this section.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/0bef9e6970a502525c16ee09f7c64bdab2355f8172cbec4e4d194075807773c1.pdf",
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      "source_sha256": "0bef9e6970a502525c16ee09f7c64bdab2355f8172cbec4e4d194075807773c1",
      "source_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FAssembly%2FMeeting+Attachments%2F040%2F25167%2FE.4.a+DFA+AR+Elective+Pass-Through+Entity+Tax+Rule+and+Act+362+of+2021.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AR.llc.treatment.s_corporation_excess_net_passive_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A qualifying S-corporation-classified LLC pays a separate entity-level tax on excess net passive income and reports it on AR1100PET line 6.",
      "fetch_event_id": null,
      "pinpoint": "2025 AR1100PET Instructions, line 6",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Line 6 - Excess Net Passive Income Tax S Corporations are subject to Arkansas income tax on excess net passive income in the same manner that such items are taxed federally. Enter the tax on Line 6 of AR1100PET and attach a schedule showing the computation of the tax. Enter the excess net passive income tax due. If the corporation has always been a Subchapter S corporation, P1 Line 6 tax does not apply. If the corporation has Ccorporation earnings and profits at year-end, passive investment income exceeding 25% of gross receipts, and taxable income, determine liability using the worksheet (complete lines 1–3 and 9); if line 2 exceeds line 3, the tax applies. Compute the tax on a separate schedule using the worksheet format (lines 1–11). The 2024 rate is 4.3%.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AR/snapshots/c50/AR/bdaef7a3db3e818674169b3d12f626e110f6d2260a632afb3e6da7d2ffd9f7e2.pdf",
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      "source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AZ.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The corporate tax base and rate are located at A.R.S. § 43-1111.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1111, complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There shall be levied, collected and paid for each taxable year upon the entire Arizona taxable income of every corporation, unless exempt under section 43-1126 or 43-1201 or as otherwise provided in this title or by law, taxes in an amount of the greater of fifty dollars or:",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AZ/5529be55f49f4249a355b40043dd13917b01957e48e8cab031d466a7ce6c87ff.html",
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      "source_sha256": "5529be55f49f4249a355b40043dd13917b01957e48e8cab031d466a7ce6c87ff",
      "source_url": "https://www.azleg.gov/ars/43/01111.htm",
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    "holding_tax:pp-holding-entity-tax#AZ.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The elective PTE tax base and rate locator is A.R.S. § 43-1014(A).",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1014(A)–(E), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning from and after December 31, 2021, the partners or shareholders of a business that is treated as a partnership or S corporation for federal income tax purposes may consent to be taxed at the entity level at a tax rate that is the same as the highest tax rate prescribed by section 43-1011 applicable to the entire portion of its taxable income that is attributable to its resident partners or shareholders and the portion of its taxable income derived from sources within this state that is attributable to its nonresident partners or shareholders for that taxable year. The election under this subsection is made by filing the business's return under this title.",
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      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AZ/ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62.html",
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      "source_sha256": "ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62",
      "source_url": "https://www.azleg.gov/ars/43/01014.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AZ.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The domestic-corporation dividend subtraction uses a 50%-or-more voting-control threshold.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1122(7) and (9)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Dividends received from another corporation owned or controlled directly or indirectly by a recipient corporation. For the purposes of this paragraph, \"control\" means direct or indirect ownership or control of fifty percent or more of the voting stock of the payor corporation by the recipient corporation. Dividends shall have the meaning provided in section 316 of the internal revenue code. This subtraction shall apply without regard to section 43-961, paragraph 2 and article 4 of this chapter.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AZ/snapshots/c50/AZ/699acd68b0c637b5d3c9c9fe7dabf3b622c15e15b1e5bd9f0ded4353b89b0dca.html",
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      "source_url": "https://www.azleg.gov/ars/43/01122.htm",
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    "holding_tax:pp-holding-entity-tax#AZ.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The election excludes income attributable to ineligible owner types and individual, estate, or trust owners who opt out.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1014(A)–(E), complete section",
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      "quote": "The election under subsection A of this section does not apply to the following: 1. Partners or shareholders that are not individuals, estates or trusts. The portion of the taxable income attributable to a partner or shareholder that is not an individual, estate or trust is not included in the entity-level tax under subsection A of this section. 2. Partners or shareholders who are individuals, estates or trusts and who opt out of the election pursuant to subsection D of this section. The portion of the taxable income attributable to a partner or shareholder who is an individual, estate or trust and who opts out of the election pursuant to subsection D of this section is not included in the entity-level tax under subsection A of this section.",
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      "source_url": "https://www.azleg.gov/ars/43/01014.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AZ.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "A.R.S. § 43-1111 states the current rate for taxable years beginning after December 31, 2016.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1111, complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning from and after December 31, 2016, 4.9 per cent of net income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AZ/5529be55f49f4249a355b40043dd13917b01957e48e8cab031d466a7ce6c87ff.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "5529be55f49f4249a355b40043dd13917b01957e48e8cab031d466a7ce6c87ff",
      "source_url": "https://www.azleg.gov/ars/43/01111.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AZ.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The entity-level election applies to taxable years beginning after December 31, 2021.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1014(A)–(E), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning from and after December 31, 2021, the partners or shareholders of a business that is treated as a partnership or S corporation for federal income tax purposes may consent to be taxed at the entity level at a tax rate that is the same as the highest tax rate prescribed by section 43-1011 applicable to the entire portion of its taxable income that is attributable to its resident partners or shareholders and the portion of its taxable income derived from sources within this state that is attributable to its nonresident partners or shareholders for that taxable year. The election under this subsection is made by filing the business's return under this title.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AZ/ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62",
      "source_url": "https://www.azleg.gov/ars/43/01014.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AZ.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "A corporation subject to Title 43 must file an Arizona return even when it has no federal taxable income.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-307(A) and (C)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every corporation subject to the tax imposed by this title shall make a return to the department. […] This section applies regardless of whether a corporation is required to file a return under the internal revenue code or whether the corporation has any federal taxable income for the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AZ/snapshots/c50/AZ/d5b1491115f1c115f511361ccb8ce639db405ef4ac0911c6862576da7c68307a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d5b1491115f1c115f511361ccb8ce639db405ef4ac0911c6862576da7c68307a",
      "source_url": "https://www.azleg.gov/ars/43/00307.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AZ.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The election is made on the business return, and an electing partnership or S corporation pays estimated tax as necessary.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1014(A)–(E), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The election under this subsection is made by filing the business's return under this title.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AZ/ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62",
      "source_url": "https://www.azleg.gov/ars/43/01014.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AZ.llc.tax_regime.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "A.R.S. § 29-3123, complete section",
          "quote": "A limited liability company established or a foreign limited liability company transacting business in this state pursuant to this chapter shall pay the taxes that are imposed by the laws of this state or any political subdivision of this state on domestic and foreign limited partnerships on an identical basis, except that, for the purposes of title 23, chapter 4 and title 43, a company or foreign company and its members shall be taxed as if the company or foreign company is either a partnership or a corporation or is disregarded as an entity as determined pursuant to the internal revenue code as defined in section 43-105.",
          "role": "llc_classification",
          "snapshot_path": "rigs/entity-research/structuring/discovery/AZ/snapshots/c50/AZ/94d7c984fa4030b5b4a9b2e5438b6f2eb4530cfbee39c24b656951f268bc85e5.html",
          "source_sha256": "94d7c984fa4030b5b4a9b2e5438b6f2eb4530cfbee39c24b656951f268bc85e5",
          "source_url": "https://www.azleg.gov/ars/29/03123.htm"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Arizona imposes corporate income tax on the entire Arizona taxable income of every corporation, subject to stated exemptions.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1111, complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There shall be levied, collected and paid for each taxable year upon the entire Arizona taxable income of every corporation, unless exempt under section 43-1126 or 43-1201 or as otherwise provided in this title or by law, taxes in an amount of the greater of fifty dollars or:",
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      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AZ/5529be55f49f4249a355b40043dd13917b01957e48e8cab031d466a7ce6c87ff.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "5529be55f49f4249a355b40043dd13917b01957e48e8cab031d466a7ce6c87ff",
      "source_url": "https://www.azleg.gov/ars/43/01111.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#AZ.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "A.R.S. § 29-3123, complete section",
          "quote": "A limited liability company established or a foreign limited liability company transacting business in this state pursuant to this chapter shall pay the taxes that are imposed by the laws of this state or any political subdivision of this state on domestic and foreign limited partnerships on an identical basis, except that, for the purposes of title 23, chapter 4 and title 43, a company or foreign company and its members shall be taxed as if the company or foreign company is either a partnership or a corporation or is disregarded as an entity as determined pursuant to the internal revenue code as defined in section 43-105.",
          "role": "llc_classification",
          "snapshot_path": "rigs/entity-research/structuring/discovery/AZ/snapshots/c50/AZ/94d7c984fa4030b5b4a9b2e5438b6f2eb4530cfbee39c24b656951f268bc85e5.html",
          "source_sha256": "94d7c984fa4030b5b4a9b2e5438b6f2eb4530cfbee39c24b656951f268bc85e5",
          "source_url": "https://www.azleg.gov/ars/29/03123.htm"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Eligible owners of a federally partnership- or S-corporation-treated business may elect Arizona entity-level income tax.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1014(A)–(E), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning from and after December 31, 2021, the partners or shareholders of a business that is treated as a partnership or S corporation for federal income tax purposes may consent to be taxed at the entity level at a tax rate that is the same as the highest tax rate prescribed by section 43-1011 applicable to the entire portion of its taxable income that is attributable to its resident partners or shareholders and the portion of its taxable income derived from sources within this state that is attributable to its nonresident partners or shareholders for that taxable year. The election under this subsection is made by filing the business's return under this title.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AZ/ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62",
      "source_url": "https://www.azleg.gov/ars/43/01014.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AZ.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Controlled-corporation dividends are subtracted when computing Arizona corporate taxable income.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1122(7) and (9)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Dividends received from another corporation owned or controlled directly or indirectly by a recipient corporation. For the purposes of this paragraph, \"control\" means direct or indirect ownership or control of fifty percent or more of the voting stock of the payor corporation by the recipient corporation. Dividends shall have the meaning provided in section 316 of the internal revenue code. This subtraction shall apply without regard to section 43-961, paragraph 2 and article 4 of this chapter.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/AZ/snapshots/c50/AZ/699acd68b0c637b5d3c9c9fe7dabf3b622c15e15b1e5bd9f0ded4353b89b0dca.html",
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      "source_class": "S1",
      "source_sha256": "699acd68b0c637b5d3c9c9fe7dabf3b622c15e15b1e5bd9f0ded4353b89b0dca",
      "source_url": "https://www.azleg.gov/ars/43/01122.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#AZ.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "A.R.S. § 29-3123, complete section",
          "quote": "A limited liability company established or a foreign limited liability company transacting business in this state pursuant to this chapter shall pay the taxes that are imposed by the laws of this state or any political subdivision of this state on domestic and foreign limited partnerships on an identical basis, except that, for the purposes of title 23, chapter 4 and title 43, a company or foreign company and its members shall be taxed as if the company or foreign company is either a partnership or a corporation or is disregarded as an entity as determined pursuant to the internal revenue code as defined in section 43-105.",
          "role": "llc_classification",
          "snapshot_path": "rigs/entity-research/structuring/discovery/AZ/snapshots/c50/AZ/94d7c984fa4030b5b4a9b2e5438b6f2eb4530cfbee39c24b656951f268bc85e5.html",
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      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The elective PTE provisions state no separate holding- or passive-entity treatment.",
      "fetch_event_id": null,
      "pinpoint": "A.R.S. § 43-1014(A)–(E), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning from and after December 31, 2021, the partners or shareholders of a business that is treated as a partnership or S corporation for federal income tax purposes may consent to be taxed at the entity level at a tax rate that is the same as the highest tax rate prescribed by section 43-1011 applicable to the entire portion of its taxable income that is attributable to its resident partners or shareholders and the portion of its taxable income derived from sources within this state that is attributable to its nonresident partners or shareholders for that taxable year. The election under this subsection is made by filing the business's return under this title.",
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      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/AZ/ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62.html",
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      "source_class": "S1",
      "source_sha256": "ea9779f4e1cf378a41a18fcf6ec9aed597d03df10aeff6cfc8117f47a4669d62",
      "source_url": "https://www.azleg.gov/ars/43/01014.htm",
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    "holding_tax:pp-holding-entity-tax#CA.llc.base_tax_locator.corporation_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Rate: R&TC § 23151; minimum franchise tax: § 23153; S corporation rate: § 23802(b)(1); alternative minimum tax: Chapter 2.5 (§§ 23400-23459).",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code §§ 23151, 23153; Part 11, Chapter 2 capture, Article 2",
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      "publish_status": "publish_ready",
      "quote": "(2) Except as provided in paragraph (1), for taxable years beginning on or after January 1, 2000, the tax imposed under this section shall be a tax according to or measured by net income, to be computed at the rate of 8.84 percent upon the basis of the net income for that taxable year, but not less than the minimum tax specified in Section 23153.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a.html",
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      "source_class": "S1",
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      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
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    "holding_tax:pp-holding-entity-tax#CA.llc.base_tax_locator.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The rate is set by reference to R&TC § 23151 under § 23501(c); S corporations: § 23802(b)(1); alternative minimum tax for Chapter 3 taxpayers: § 23455(a)(2).",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23501(c); Part 11, Chapter 3 capture, § 23501",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) For calendar or fiscal years ending after December 31, 1979, the rate of tax shall be the rate specified for those years by Section 23151.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/698b9f99a669fc5a2ad79724825ac34622680e243462bcec42a987b991006eed.html",
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      "source_class": "S1",
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      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=3.&article=",
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    "holding_tax:pp-holding-entity-tax#CA.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The rate is in R&TC § 19910(a)(1), qualified net income is defined in § 19910(a)(2), and payment dates are in § 19914.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 19910(a); Part 10.4.1 capture, § 19910",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) (1) For taxable years beginning on or after January 1, 2026, and before January 1, 2031, a qualified entity doing business in this state, as defined in Section 23101, and that is required to file a return under Section 18633, 18633.5, or subdivision (a) of Section 18601, may elect to annually pay an elective tax according to or measured by its qualified net income, defined in paragraph (2), computed at the rate of 9.3 percent for the taxable year for which the election is made.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.base_tax_locator.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The amount is set by reference to R&TC § 23153(d) under § 17941(a); § 17941(g) states first-taxable-year rules.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17941(a); Part 10, Chapter 10.6 capture, § 17941",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Except as provided in subdivision (g), for each taxable year beginning on or after January 1, 1997, a limited liability company doing business in this state (as defined in Section 23101) shall pay annually to this state a tax for the privilege of doing business in this state in an amount equal to the applicable amount specified in subdivision (d) of Section 23153 for the taxable year.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
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      "source_class": "S1",
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      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#CA.llc.base_tax_locator.llc_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Fee tiers are in R&TC § 17942(a)(1)-(4); the income measure and its assignment to California are in § 17942(b).",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17942(a)-(b); Part 10, Chapter 10.6 capture, § 17942",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) In addition to the tax imposed under Section 17941, every limited liability company subject to tax under Section 17941 shall pay annually to this state a fee equal to:",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.base_tax_locator.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The rate is set by reference to R&TC § 23151 under § 23811(b)(1), with a financial-corporation adjustment in (b)(2); the base follows IRC § 1375 as modified.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23811(b); Part 11, Chapter 4.5 capture, § 23811",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) (1) The rate of tax shall be equal to the rate of tax imposed under Section 23151 in lieu of Section 11(b) of the Internal Revenue Code.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3d0e7c6296ec34d68cc668837c43681b4a95df0e9fe8498ce40de8da11811c96.html",
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      "source_class": "S1",
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      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.does_not_reach.corporation_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 23040.1(a)(2), (b)(2); Part 11, Chapter 1 capture, § 23040.1",
          "quote": "This paragraph does not apply to a dealer in stocks or securities. […] (2) Paragraph (2) of subdivision (a) does not apply to an alien corporation that itself has, or that is engaged in a unitary business with another corporation that has, income derived from or attributable to sources within this state other than income described in paragraph (2) of subdivision (a).",
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          "source_sha256": "e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article="
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "§ 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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23102 (Part 11, Chapter 2 capture, Article 1); § 23040.1(a)(2), (b)(2) (Chapter 1 capture)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "and not trading in stock or bonds or other securities held, and engaging in no activities other than the receipt and disbursement of dividends from stock or interest from bonds, is not a corporation doing business in this State for the purposes of this chapter.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.does_not_reach.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "§ 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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23040.1(a)(2), (b), (d)(4)(B); Part 11, Chapter 1 capture, § 23040.1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) (1) Paragraph (1) of subdivision (a) shall not apply to a corporation that participates in the management of the investment activities of the investment partnership or that is engaged in a unitary business with another corporation or partnership that participates in the management of the investment activities of the partnership or has income derived from or attributable to sources within this state other than income described in paragraph (1) of subdivision (a). […] (2) Paragraph (2) of subdivision (a) does not apply to an alien corporation that itself has, or that is engaged in a unitary business with another corporation that has, income derived from or attributable to sources within this state other than income described in paragraph (2) of subdivision (a).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R&TC Parts 10.4.1 (§§ 19910-19916) and 10.4 (§§ 19900-19907), full text",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.does_not_reach.llc_annual_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code §§ 23701h(a), (b)(2), 23701x(a); Part 11, Chapter 4, Article 1 capture",
          "quote": "(a) A corporation described in Section 501(c)(2) of the Internal Revenue Code, relating to certain title-holding companies. […] (2) A limited liability company that, under the authority of this section, is exempt from the tax imposed by this part is also exempt from the tax and fees imposed under Chapter 10.6 (commencing with Section 17941) of Part 10. […] (a) A corporation or trust described in Section 501(c)(25) of the Internal Revenue Code, relating to certain title-holding companies.",
          "role": "title_holding_exemption_limited_to_exempt_owned_entities",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/da756cbfbf4323f5970d61dd311c0325eea8926207033d22fd595d4814b7f93a.html",
          "source_sha256": "da756cbfbf4323f5970d61dd311c0325eea8926207033d22fd595d4814b7f93a",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.&article="
        },
        {
          "pinpoint": "FTB 2025 Form 568 booklet, General Information F, Limited Liability Company Tax and Fee",
          "quote": "The definition of limited liability company has been revised to exclude certain title holding companies that are tax exempt provided that they are treated as partnerships or disregarded entities for tax purposes. As such they are not liable for the annual LLC tax and fee.",
          "role": "agency_guidance",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/18258a7dcb2f02c7ae857634a39ab1dfe837c3c9fb464f03177b0664f0166d6d.html",
          "source_sha256": "18258a7dcb2f02c7ae857634a39ab1dfe837c3c9fb464f03177b0664f0166d6d",
          "source_url": "https://www.ftb.ca.gov/forms/2025/2025-568-booklet.html"
        },
        {
          "pinpoint": "FTB Publication 927, Exempt Organizations table (Title holders – limited liability companies) and Limited Liability Companies section",
          "quote": "Title holders – limited liability companies including single and multiple members As defined in R&TC Section 23701h and 23701x, they must apply for and receive a determination letter from us. Must be owned and operated exclusively by a nonprofit organization. They may be classified as a disregarded entity, multiple member, or association. […] Limited Liability Companies (LLC) seeking tax-exempt status must be owned and operated exclusively by a nonprofit organization. LLCs who have members that are a stock corporation or individuals are not permitted tax-exempt status.",
          "role": "agency_guidance",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/a3f06ee45b9b9e743fe665a88dc856a0efc63c264cd1c34031e55ab348e886fc.html",
          "source_sha256": "a3f06ee45b9b9e743fe665a88dc856a0efc63c264cd1c34031e55ab348e886fc",
          "source_url": "https://www.ftb.ca.gov/forms/misc/927.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17941(d) (Part 10, Chapter 10.6 capture); §§ 23701h(a), (b)(2), 23701x(a) (Part 11, Chapter 4 capture)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(d) For purposes of this section, “limited liability company” means an organization, other than a limited liability company that is exempt from the tax and fees imposed under this chapter pursuant to Section 23701h or Section 23701x",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.does_not_reach.llc_fee": {
      "additional_sources": [
        {
          "pinpoint": "FTB 2025 Form 568 booklet, Schedule IW instructions (Alternative Methods; Pass-through Entities)",
          "quote": "The rules contained in R&TC Section 25137(c) that serve to remove items from assignment in their totality are not applicable to the determination of income derived from or attributable to California. […] Pass-through Entities. LLCs with ownership interest in a pass-through entity, other than an LLC, must report their distributive share of the pass-through entity’s \"Total Income from all sources derived from or attributable to this state.\"",
          "role": "agency_guidance",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/18258a7dcb2f02c7ae857634a39ab1dfe837c3c9fb464f03177b0664f0166d6d.html",
          "source_sha256": "18258a7dcb2f02c7ae857634a39ab1dfe837c3c9fb464f03177b0664f0166d6d",
          "source_url": "https://www.ftb.ca.gov/forms/2025/2025-568-booklet.html"
        },
        {
          "pinpoint": "FTB Publication 927, Limited Liability Companies section",
          "quote": "Limited Liability Companies (LLC) seeking tax-exempt status must be owned and operated exclusively by a nonprofit organization. LLCs who have members that are a stock corporation or individuals are not permitted tax-exempt status.",
          "role": "agency_guidance",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/a3f06ee45b9b9e743fe665a88dc856a0efc63c264cd1c34031e55ab348e886fc.html",
          "source_sha256": "a3f06ee45b9b9e743fe665a88dc856a0efc63c264cd1c34031e55ab348e886fc",
          "source_url": "https://www.ftb.ca.gov/forms/misc/927.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code §§ 17942(b)(1)(A)-(B), 17941(d); Part 10, Chapter 10.6 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "if the allocation or attribution of income or gain or distributions are directly or indirectly attributable to income that is subject to the payment of the fee described in this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.does_not_reach.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code §§ 23811(a), 23801(g); Part 11, Chapter 4.5 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) The tax imposed under this section may not be imposed on an “S corporation” that has no excess net passive income for federal income tax purposes determined in accordance with Section 1375 of the Internal Revenue Code. […] (g) Section 1362(d)(3) of the Internal Revenue Code, relating to circumstances where passive investment income exceeds 25 percent of gross receipts for three consecutive taxable years and the corporation has accumulated earnings and profits, does not apply unless the “S” election is terminated for federal income tax purposes.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3d0e7c6296ec34d68cc668837c43681b4a95df0e9fe8498ce40de8da11811c96.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3d0e7c6296ec34d68cc668837c43681b4a95df0e9fe8498ce40de8da11811c96",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.effective_period.corporation_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 23040.1(e) and history note; Part 11, Chapter 1 capture, § 23040.1",
          "quote": "(e) The amendments made to this section by the act adding this subdivision shall apply to taxable years beginning on or after January 1, 1999. […] (Amended by Stats. 2001, Ch. 543, Sec. 23. Effective January 1, 2002.)",
          "role": "carve_out_effective_date",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124.html",
          "source_sha256": "e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article="
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code §§ 23151(f)(2), 23101(b), 23102 history note (Part 11, Chapter 2 capture); § 23040.1(e) (Chapter 1 capture)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "for taxable years beginning on or after January 1, 2000, the tax imposed under this section shall be a tax according to or measured by net income […] (b) For taxable years beginning on or after January 1, 2011, a taxpayer is doing business in this state for a taxable year if any of the following conditions has been satisfied: […] (Amended by Stats. 1951, Ch. 72.)",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.effective_period.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 23040.1(e) and history note; Part 11, Chapter 1 capture, § 23040.1",
          "quote": "(e) The amendments made to this section by the act adding this subdivision shall apply to taxable years beginning on or after January 1, 1999. […] (Amended by Stats. 2001, Ch. 543, Sec. 23. Effective January 1, 2002.)",
          "role": "carve_out_effective_date",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124.html",
          "source_sha256": "e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article="
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "§ 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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23501(a) (Part 11, Chapter 3 capture, § 23501); § 23040.1(e) (Chapter 1 capture)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "upon its net income derived from sources within this state on or after January 1, 1937",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/698b9f99a669fc5a2ad79724825ac34622680e243462bcec42a987b991006eed.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "698b9f99a669fc5a2ad79724825ac34622680e243462bcec42a987b991006eed",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=3.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code §§ 19900(a)(1), 19906(a); Part 10.4 capture",
          "quote": "(a) (1) For taxable years beginning on or after January 1, 2021, and before January 1, 2026, a qualified entity doing business in this state […] (a) Except as provided in subdivision (b), this part shall remain in effect only until December 1, 2026, and as of that date is repealed.",
          "role": "predecessor_part",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/7aaabe603f2205ae69c0929223f5fcec647c84c4d250bd12d1ec024fc6c29cc7.html",
          "source_sha256": "7aaabe603f2205ae69c0929223f5fcec647c84c4d250bd12d1ec024fc6c29cc7",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.&chapter=&article="
        },
        {
          "pinpoint": "FTB 2026 Instructions for Form FTB 3893, What's New",
          "quote": "Extended – For taxable years beginning on or after January 1, 2026, and before January 1, 2031, the pass-through entity (PTE) elective tax and credit for qualified taxpayers is extended.",
          "role": "agency_guidance",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/207693bb8b18530bb7165dd06293f68b681cf1b120dd89a0c8dc8289408195c3.pdf",
          "source_sha256": "207693bb8b18530bb7165dd06293f68b681cf1b120dd89a0c8dc8289408195c3",
          "source_url": "https://www.ftb.ca.gov/forms/2026/2026-3893-instructions.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code §§ 19910(a)(1), 19916 (Part 10.4.1 capture); §§ 19900(a)(1), 19906(a) (Part 10.4 capture)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) (1) For taxable years beginning on or after January 1, 2026, and before January 1, 2031, a qualified entity doing business in this state […] (a) This part shall only become operative if the operation of Section 164(b)(6) of the Internal Revenue Code, relating to the limitation on individual deductions for taxable years 2018 through 2025, is extended. (b) Except as provided in subdivision (c), this part shall remain in effect only until December 1, 2031, and as of that date is repealed.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.effective_period.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The annual tax applies to taxable years beginning on or after January 1, 1997; § 17941 was last amended effective July 13, 2026.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17941(a) and its history note; Part 10, Chapter 10.6 capture, § 17941",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "for each taxable year beginning on or after January 1, 1997, a limited liability company doing business in this state (as defined in Section 23101) shall pay annually […] (Amended by Stats. 2026, Ch. 85, Sec. 7. (SB 180) Effective July 13, 2026.)",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.effective_period.llc_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "§ 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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17943; § 17942 history note; Part 10, Chapter 10.6 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "It is the intent of the Legislature that the amount of the annual fee described in Section 17942 shall apply to the taxable year beginning January 1, 2001, and subsequent taxable years, notwithstanding the results of any study prepared by the Franchise Tax Board and submitted to the Joint Legislative Budget Committee pursuant to former Section 17943.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.effective_period.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23811 history note; Part 11, Chapter 4.5 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(Amended by Stats. 2003, Ch. 268, Sec. 13. Effective January 1, 2004.)",
      "readiness": "ready",
      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3d0e7c6296ec34d68cc668837c43681b4a95df0e9fe8498ce40de8da11811c96.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3d0e7c6296ec34d68cc668837c43681b4a95df0e9fe8498ce40de8da11811c96",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.filing_rule.corporation_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 23772(a)(1); Part 11, Chapter 4, Article 3 capture, § 23772",
          "quote": "(1) Except as provided in paragraph (2), every organization exempt from taxation under Section 23701 and every trust treated as a private foundation because of Section 4947(a)(1) of the Internal Revenue Code shall file an annual return, stating specifically the items of gross income, receipts, and disbursements, and any other information for the purpose of carrying out the laws under this part as the Franchise Tax Board may by rules or regulations prescribe, and shall keep any records, render under oath any statements, make any other returns, and comply with any rules and regulations as the Franchise Tax Board may from time to time prescribe. The return shall be filed on or before the 15th day of the fifth full calendar month following the close of the taxable year.",
          "role": "exempt_organization_return",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/da756cbfbf4323f5970d61dd311c0325eea8926207033d22fd595d4814b7f93a.html",
          "source_sha256": "da756cbfbf4323f5970d61dd311c0325eea8926207033d22fd595d4814b7f93a",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.&article="
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 18601(a); Part 10.2, Chapter 2, Article 2 capture, § 18601",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Except as provided in subdivision (b), (c), or (d), every taxpayer subject to the tax imposed by Part 11 (commencing with Section 23001) shall, on or before the 15th day of the fourth month following the close of its taxable year, transmit to the Franchise Tax Board a return in a form prescribed by it, specifying for the taxable year, all the facts as it may by rule, or otherwise, require in order to carry out this part.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.2.&chapter=2.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.filing_rule.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 23772(a)(1); Part 11, Chapter 4, Article 3 capture, § 23772",
          "quote": "(1) Except as provided in paragraph (2), every organization exempt from taxation under Section 23701 and every trust treated as a private foundation because of Section 4947(a)(1) of the Internal Revenue Code shall file an annual return, stating specifically the items of gross income, receipts, and disbursements, and any other information for the purpose of carrying out the laws under this part as the Franchise Tax Board may by rules or regulations prescribe, and shall keep any records, render under oath any statements, make any other returns, and comply with any rules and regulations as the Franchise Tax Board may from time to time prescribe. The return shall be filed on or before the 15th day of the fifth full calendar month following the close of the taxable year.",
          "role": "exempt_organization_return",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/da756cbfbf4323f5970d61dd311c0325eea8926207033d22fd595d4814b7f93a.html",
          "source_sha256": "da756cbfbf4323f5970d61dd311c0325eea8926207033d22fd595d4814b7f93a",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.&article="
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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)).",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 18601(a); Part 10.2, Chapter 2, Article 2 capture, § 18601",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Except as provided in subdivision (b), (c), or (d), every taxpayer subject to the tax imposed by Part 11 (commencing with Section 23001) shall, on or before the 15th day of the fourth month following the close of its taxable year, transmit to the Franchise Tax Board a return in a form prescribed by it, specifying for the taxable year, all the facts as it may by rule, or otherwise, require in order to carry out this part. […] A tax return, disclosing net income for any taxable year, filed pursuant to Chapter 2 (commencing with Section 23101) or Chapter 3 (commencing with Section 23501) of Part 11 shall be deemed filed pursuant to the proper chapter of Part 11 for the same taxable period, if the chapter under which the return is filed is determined erroneous.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.2.&chapter=2.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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)).",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code §§ 19910(d), 19914(d); Part 10.4.1 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(d) The election shall be irrevocable and shall be made on an original, timely filed return required under Part 10.2 (commencing with Section 18401) for the taxable year of the election in the form and manner as prescribed by the Franchise Tax Board. […] (d) This part shall not change any filing requirements under Part 10 (commencing with Section 17001), Part 10.2 (commencing with Section 18401), or Part 11 (commencing with Section 23001).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.filing_rule.llc_annual_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 18633.5(a), (i)(1); Part 10.2, Chapter 2, Article 4 capture, § 18633.5",
          "quote": "(a) Every limited liability company that is classified as a partnership for California tax purposes that is doing business in this state, organized in this state, or registered with the Secretary of State shall file its return on or before the 15th day of the third month following the close of its taxable year, stating specifically the items of gross income and the deductions allowed by Part 10 (commencing with Section 17001). […] (i) (1) Every limited liability company doing business in this state, organized in this state, or registered with the Secretary of State, that is disregarded pursuant to Section 23038 shall file a return that includes information necessary to verify its liability under Sections 17941 and 17942, provides its sole owner’s name and taxpayer identification number, includes the consent of the owner to California tax jurisdiction, and includes other information necessary for the administration of this part, Part 10 (commencing with Section 17001), or Part 11 (commencing with Section 23001).",
          "role": "llc_return_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3.html",
          "source_sha256": "470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.2.&chapter=2.&article="
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23772(a)(1), (a)(2)(A)(ii); Part 11, Chapter 4, Article 3 capture, § 23772",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) Except as provided in paragraph (2), every organization exempt from taxation under Section 23701 and every trust treated as a private foundation because of Section 4947(a)(1) of the Internal Revenue Code shall file an annual return, stating specifically the items of gross income, receipts, and disbursements, and any other information for the purpose of carrying out the laws under this part as the Franchise Tax Board may by rules or regulations prescribe, and shall keep any records, render under oath any statements, make any other returns, and comply with any rules and regulations as the Franchise Tax Board may from time to time prescribe. The return shall be filed on or before the 15th day of the fifth full calendar month following the close of the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/da756cbfbf4323f5970d61dd311c0325eea8926207033d22fd595d4814b7f93a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "da756cbfbf4323f5970d61dd311c0325eea8926207033d22fd595d4814b7f93a",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.filing_rule.llc_fee": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 18633.5(i)(1); Part 10.2, Chapter 2, Article 4 capture, § 18633.5",
          "quote": "(i) (1) Every limited liability company doing business in this state, organized in this state, or registered with the Secretary of State, that is disregarded pursuant to Section 23038 shall file a return that includes information necessary to verify its liability under Sections 17941 and 17942, provides its sole owner’s name and taxpayer identification number, includes the consent of the owner to California tax jurisdiction, and includes other information necessary for the administration of this part, Part 10 (commencing with Section 17001), or Part 11 (commencing with Section 23001).",
          "role": "llc_return_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3.html",
          "source_sha256": "470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.2.&chapter=2.&article="
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17942(c), (d)(1); Part 10, Chapter 10.6 capture, § 17942",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) The fee assessed under this section shall be due and payable on the date the return of the limited liability company is required to be filed under Section 18633.5, shall be collected and refunded in the same manner as the taxes imposed by this part, and shall be subject to interest and applicable penalties. […] (d) (1) The fee imposed by this section shall be estimated and paid on or before the 15th day of the sixth month of the current taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.filing_rule.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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)).",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 18601(a), (d)(1); Part 10.2, Chapter 2, Article 2 capture, § 18601",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Except as provided in subdivision (b), (c), or (d), every taxpayer subject to the tax imposed by Part 11 (commencing with Section 23001) shall, on or before the 15th day of the fourth month following the close of its taxable year, transmit to the Franchise Tax Board a return in a form prescribed by it, specifying for the taxable year, all the facts as it may by rule, or otherwise, require in order to carry out this part. […] (d) (1) In the case of an “S corporation” described in Section 1361 of the Internal Revenue Code, relating to S corporation defined, returns shall be filed on or before the 15th day of the third month following the close of its taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "470bb2d3414c145d62d704dbf45988abf783a42e104fd83d74198a9d9c81c6a3",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.2.&chapter=2.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.tax_regime.corporation_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 23038(c); Part 11, Chapter 1 capture, § 23038",
          "quote": "(c) In addition to the above, for purposes of the tax imposed under Chapter 2 (commencing with Section 23101) for the purpose of exercising its franchise within this state, “corporation” also includes any limited liability company that is classified as an association for California tax purposes.",
          "role": "llc_tax_classification",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124.html",
          "source_sha256": "e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article="
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23151(a), (f)(2); Part 11, Chapter 2 capture, Article 2, § 23151",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) With the exception of banks and financial corporations, every corporation doing business within the limits of this state and not expressly exempted from taxation by the provisions of the Constitution of this state or by this part, shall annually pay to the state, for the privilege of exercising its corporate franchises within this state, a tax according to or measured by its net income, to be computed at the rate of 7.6 percent upon the basis of its net income for the next preceding income year, or if greater, the minimum tax specified in Section 23153. […] (2) Except as provided in paragraph (1), for taxable years beginning on or after January 1, 2000, the tax imposed under this section shall be a tax according to or measured by net income, to be computed at the rate of 8.84 percent upon the basis of the net income for that taxable year, but not less than the minimum tax specified in Section 23153.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.tax_regime.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 23038(b)(2)(A), (B)(ii); Part 11, Chapter 1 capture, § 23038",
          "quote": "(2) (A) For the purposes of the tax imposed under Chapter 3 (commencing with Section 23501), “corporation” also includes associations (other than banking associations but including nonprofit associations that perform services, borrow money or own property), business trusts, and other business entities classified as associations. […] (ii) The classification of an eligible business entity as a partnership or an association taxable as a corporation for purposes of this part, Part 10 (commencing with Section 17001), and Part 10.2 (commencing with Section 18401) shall be the same as the classification of the entity for federal tax purposes.",
          "role": "llc_tax_classification",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124.html",
          "source_sha256": "e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article="
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23501(a), (c); Part 11, Chapter 3 capture, § 23501",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) There shall be imposed upon every corporation, other than a bank, for each taxable year, a tax at the rate of 7.6 percent upon its net income derived from sources within this state on or after January 1, 1937, other than income for any period for which the corporation is subject to taxation under Chapter 2 (commencing with Section 23101), according to or measured by its net income. […] (c) For calendar or fiscal years ending after December 31, 1979, the rate of tax shall be the rate specified for those years by Section 23151.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/698b9f99a669fc5a2ad79724825ac34622680e243462bcec42a987b991006eed.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "698b9f99a669fc5a2ad79724825ac34622680e243462bcec42a987b991006eed",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=3.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Cal. Rev. & Tax. Code § 19900(a)(1); Part 10.4 capture, § 19900",
          "quote": "(a) (1) For taxable years beginning on or after January 1, 2021, and before January 1, 2026, a qualified entity doing business in this state",
          "role": "predecessor_part",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/7aaabe603f2205ae69c0929223f5fcec647c84c4d250bd12d1ec024fc6c29cc7.html",
          "source_sha256": "7aaabe603f2205ae69c0929223f5fcec647c84c4d250bd12d1ec024fc6c29cc7",
          "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.&chapter=&article="
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 19910(a)(1); Part 10.4.1 capture, § 19910",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) (1) For taxable years beginning on or after January 1, 2026, and before January 1, 2031, a qualified entity doing business in this state, as defined in Section 23101, and that is required to file a return under Section 18633, 18633.5, or subdivision (a) of Section 18601, may elect to annually pay an elective tax according to or measured by its qualified net income, defined in paragraph (2), computed at the rate of 9.3 percent for the taxable year for which the election is made.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.tax_regime.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17941(a)-(b)(1); Part 10, Chapter 10.6 capture, § 17941",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Except as provided in subdivision (g), for each taxable year beginning on or after January 1, 1997, a limited liability company doing business in this state (as defined in Section 23101) shall pay annually to this state a tax for the privilege of doing business in this state in an amount equal to the applicable amount specified in subdivision (d) of Section 23153 for the taxable year. (b) (1) In addition to any limited liability company that is doing business in this state and is therefore subject to the tax imposed by subdivision (a), for each taxable year beginning on or after January 1, 1997, a limited liability company shall pay annually the tax prescribed in subdivision (a) if articles of organization have been accepted, or a certificate of registration has been issued, by the office of the Secretary of State.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.tax_regime.llc_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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)).",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17942(a); Part 10, Chapter 10.6 capture, § 17942",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) In addition to the tax imposed under Section 17941, every limited liability company subject to tax under Section 17941 shall pay annually to this state a fee equal to: (1) Nine hundred dollars ($900), if the total income from all sources derived from or attributable to this state for the taxable year is two hundred fifty thousand dollars ($250,000) or more, but less than five hundred thousand dollars ($500,000). (2) Two thousand five hundred dollars ($2,500), if the total income from all sources derived from or attributable to this state for the taxable year is five hundred thousand dollars ($500,000) or more, but less than one million dollars ($1,000,000). (3) Six thousand dollars ($6,000), if the total income from all sources derived from or attributable to this state for the taxable year is one million dollars ($1,000,000) or more, but less than five million dollars ($5,000,000). (4) Eleven thousand seven hundred ninety dollars ($11,790), if the total income from all sources derived from or attributable to this state for the taxable year is five million dollars ($5,000,000) or more.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.tax_regime.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23811 (lead-in, (a), (b)(1)); Part 11, Chapter 4.5 capture, § 23811",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as otherwise provided in this section, there is hereby imposed a tax on passive investment income attributable to California sources, determined in accordance with the provisions of Section 1375 of the Internal Revenue Code, relating to tax imposed on passive investment income, as modified by this section. (a) The tax imposed under this section may not be imposed on an “S corporation” that has no excess net passive income for federal income tax purposes determined in accordance with Section 1375 of the Internal Revenue Code. (b) (1) The rate of tax shall be equal to the rate of tax imposed under Section 23151 in lieu of Section 11(b) of the Internal Revenue Code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3d0e7c6296ec34d68cc668837c43681b4a95df0e9fe8498ce40de8da11811c96.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3d0e7c6296ec34d68cc668837c43681b4a95df0e9fe8498ce40de8da11811c96",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.treatment.corporation_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "FTB Multistate Audit Technical Manual 1310, Doing Business (chapter 1000 PDF)",
          "quote": "In addition, R&TC §23102 provides that a holding company organized to hold stock or bonds will not be considered to be \"doing business\" if its only activities are the receipt of dividends or interest, and the disbursement of those receipts to shareholders. To qualify under this exception, the holding company may not engage in trading the stock, bonds or other securities that it holds.",
          "role": "agency_guidance",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/7f7a41a2e1118eee32e97ccfb13481e65a254655db0c34e65b6cd37503ca5fcf.pdf",
          "source_sha256": "7f7a41a2e1118eee32e97ccfb13481e65a254655db0c34e65b6cd37503ca5fcf",
          "source_url": "https://www.ftb.ca.gov/tax-pros/procedures/multistate-audit-technical-manual/chapter-1000.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "§ 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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code §§ 23102, 23153(a)-(b); Part 11, Chapter 2 capture, Articles 1-2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Any corporation holding or organized to hold stock or bonds of any other corporation or corporations, and not trading in stock or bonds or other securities held, and engaging in no activities other than the receipt and disbursement of dividends from stock or interest from bonds, is not a corporation doing business in this State for the purposes of this chapter. […] (a) Every corporation described in subdivision (b) shall be subject to the minimum franchise tax specified in subdivision (d) from the earlier of the date of incorporation, qualification, or commencing to do business within this state, until the effective date of dissolution or withdrawal as provided in Section 23331 or, if later, the date the corporation ceases to do business within the limits of this state. (b) Unless expressly exempted by this part or the California Constitution, subdivision (a) shall apply to each of the following: (1) Every corporation that is incorporated under the laws of this state. (2) Every corporation that is qualified to transact intrastate business in this state pursuant to Chapter 21 (commencing with Section 2100) of Division 1 of Title 1 of the Corporations Code. (3) Every corporation that is doing business in this state.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "07b7cfa7badc7b4bca1049b81590257e020b9aa96d7a8bc27c0db4c61e95b40a",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.treatment.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "§ 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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 23040.1(a); Part 11, Chapter 1 capture, § 23040.1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Notwithstanding Sections 23040 and 25101, income derived from or attributable to sources within this state shall not include: […] (1) The distributive share of interest, dividends, and gains from the sale or exchange of qualifying investment securities derived by a corporation that is a partner in a partnership that qualifies as an investment partnership under Section 17955, whether or not the partnership has a usual place of business in this state, if the income from the partnership is the corporation’s only income derived from or attributable to sources within this state. […] (2) Income, gain, or loss from stocks or securities received by an alien corporation whose sole activities in this state involve trading in those stocks or securities for the corporation’s own account within the meaning of Section 864(b)(2)(A)(ii) of the Internal Revenue Code, whether the trading is done by the corporation or its employees or through a resident broker, commission agent, custodian, or other agent, and whether or not any employee or agent has discretionary authority to make decisions in effecting the transactions. This paragraph does not apply to a dealer in stocks or securities.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "e185a37d396727bcbfd6ee62b3e30b8cfba8424df365bba0cf7f9204dffe1124",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 19910(a)(1); Part 10.4.1 capture, § 19910; Parts 10.4.1 and 10.4 full text searched",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "may elect to annually pay an elective tax according to or measured by its qualified net income",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e75b58443ed5afbf08e686f87b706f2a2cfded46aa32536477555c3b516773c",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.treatment.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17941(a)-(b)(1); Part 10, Chapter 10.6 capture, § 17941",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Except as provided in subdivision (g), for each taxable year beginning on or after January 1, 1997, a limited liability company doing business in this state (as defined in Section 23101) shall pay annually to this state a tax for the privilege of doing business in this state in an amount equal to the applicable amount specified in subdivision (d) of Section 23153 for the taxable year. (b) (1) In addition to any limited liability company that is doing business in this state and is therefore subject to the tax imposed by subdivision (a), for each taxable year beginning on or after January 1, 1997, a limited liability company shall pay annually the tax prescribed in subdivision (a) if articles of organization have been accepted, or a certificate of registration has been issued, by the office of the Secretary of State.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.treatment.llc_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code § 17942(b)(1)(A); Part 10, Chapter 10.6 capture, § 17942",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "However, “total income from all sources derived from or attributable to this state” shall not include allocation or attribution of income or gain or distributions made to a limited liability company in its capacity as a member of, or holder of an economic interest in, another limited liability company if the allocation or attribution of income or gain or distributions are directly or indirectly attributable to income that is subject to the payment of the fee described in this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "819d9ecadc5fdfee749ba3489caa0111635625486f445ace32f7f460e6f31b0e",
      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CA.llc.treatment.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Cal. Rev. & Tax. Code §§ 23811 (lead-in, (b)(1)), 23802(e); Part 11, Chapter 4.5 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "there is hereby imposed a tax on passive investment income attributable to California sources, determined in accordance with the provisions of Section 1375 of the Internal Revenue Code, relating to tax imposed on passive investment income […] (b) (1) The rate of tax shall be equal to the rate of tax imposed under Section 23151 in lieu of Section 11(b) of the Internal Revenue Code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CA/snapshots/c50/CA/3d0e7c6296ec34d68cc668837c43681b4a95df0e9fe8498ce40de8da11811c96.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate income-tax base and rate schedule are located in §39-22-301(1)(d)(I).",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-301(1)(d)(I)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(d) (I) A tax is imposed upon each domestic C corporation, foreign C corporation, and combined group, as defined in section 39-22-303 (12)(a.3), doing business in Colorado annually in an amount of the net income of such C corporation during the year derived from sources within Colorado as set forth in the following schedule of rates:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective PTE tax base and rate cross-reference are located in §39-22-344(1).",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-344(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) With respect to any taxable period for which it has made the election under section 39-22-343, an electing pass-through entity is subject to a tax in an amount equal to the tax rate set forth in section 39-22-301 for the applicable income tax year multiplied by the sum of the following, all as determined pursuant to sections 39-22-202, 39-22-203, 39-22-322, and 39-22-323: (a) Each electing pass-through entity owner's pro rata or distributive share of the electing pass-through entity's income attributable to the state; and (b) Each resident electing pass-through entity owner's pro rata or distributive share of the electing pass-through entity's income not attributable to the state.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No special statutory limit for holding or passive entities was located in the complete C-corporation income-tax subpart.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No special statutory limit for holding or passive entities was located in the complete SALT Parity Act subpart.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current statutory rate provision applies to income-tax years commencing on or after January 1, 2022, subject to §39-22-627.",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-301(1)(d)(I)(K)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(K) Except as otherwise provided in section 39-22-627, for income tax years commencing on or after January 1, 2022, four and forty one-hundredths percent of the Colorado net income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Colo. Rev. Stat. §39-22-343(2)",
          "quote": "(2) The election allowed under subsection (1) of this section is only allowed in an income tax year where there is a limitation on the deductions allowed to individuals under section 164 of the internal revenue code.",
          "role": "supporting",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
          "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
          "source_url": "https://olls.info/crs/crs2026-title-39.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The annual election applies for income-tax years beginning on or after January 1, 2018, but only while the federal §164 deduction limitation exists.",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-343(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) (a) Notwithstanding sections 39-22-201, 39-22-302, and 39-22-322, and except as provided in subsection (2) of this section, for income tax years commencing on or after January 1, 2018, an S corporation or partnership may annually elect to be subject to tax at the entity level for the taxable period.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Every C corporation subject to the article must file a return reporting federal taxable income, Colorado modifications and credits, and required information.",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-601(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) Every C corporation subject to taxation under this article shall make a return which shall contain a written declaration that it is made under the penalties of perjury in the second degree. Such return shall set forth, in such detail as the executive director shall prescribe by regulations, federal taxable income and the modifications and credits required or allowed under this article and any other information necessary to carry out the purposes of this article. The return shall be signed by the president, vice-president, treasurer, assistant treasurer, chief accounting officer, or other officer duly authorized to act. In cases where receivers, trustees in bankruptcy, or assignees are operating the property or business of corporations, such receivers, trustees, or assignees shall make returns for such corporations in the same manner and form as corporations are required to make returns. Any tax due on the basis of such returns shall be collected in the same manner as if collected from the corporation for which the return is made.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The S corporation or partnership makes the annual election on its §39-22-601 return, and that filed election binds all electing owners.",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-343(1)(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) Except as set forth in subsection (1)(c)(I) of this section, the S corporation or partnership shall make the election on the return filed by such S corporation or partnership under section 39-22-601. The filing of a return filed under section 39-22-601 or subsection (1)(c)(I) of this section is binding on all electing pass-through entity owners.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Colorado imposes an annual income tax on each domestic or foreign C corporation and combined group doing business in Colorado.",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-301(1)(d)(I)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(d) (I) A tax is imposed upon each domestic C corporation, foreign C corporation, and combined group, as defined in section 39-22-303 (12)(a.3), doing business in Colorado annually in an amount of the net income of such C corporation during the year derived from sources within Colorado as set forth in the following schedule of rates:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-344(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) With respect to any taxable period for which it has made the election under section 39-22-343, an electing pass-through entity is subject to a tax in an amount equal to the tax rate set forth in section 39-22-301 for the applicable income tax year multiplied by the sum of the following, all as determined pursuant to sections 39-22-202, 39-22-203, 39-22-322, and 39-22-323: (a) Each electing pass-through entity owner's pro rata or distributive share of the electing pass-through entity's income attributable to the state; and (b) Each resident electing pass-through entity owner's pro rata or distributive share of the electing pass-through entity's income not attributable to the state.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The generally applicable corporate income tax applies; no holding-entity carve-out was located in the complete C-corporation subpart.",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-301(1)(d)(I)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(d) (I) A tax is imposed upon each domestic C corporation, foreign C corporation, and combined group, as defined in section 39-22-303 (12)(a.3), doing business in Colorado annually in an amount of the net income of such C corporation during the year derived from sources within Colorado as set forth in the following schedule of rates:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CO.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective tax uses the stated owner-share income base; no holding-entity carve-out from that base was located in the complete subpart.",
      "fetch_event_id": null,
      "pinpoint": "Colo. Rev. Stat. §39-22-344(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) With respect to any taxable period for which it has made the election under section 39-22-343, an electing pass-through entity is subject to a tax in an amount equal to the tax rate set forth in section 39-22-301 for the applicable income tax year multiplied by the sum of the following, all as determined pursuant to sections 39-22-202, 39-22-203, 39-22-322, and 39-22-323: (a) Each electing pass-through entity owner's pro rata or distributive share of the electing pass-through entity's income attributable to the state; and (b) Each resident electing pass-through entity owner's pro rata or distributive share of the electing pass-through entity's income not attributable to the state.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CO/snapshots/c50/CO/4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4bd401ea10ed5ce5e316e9aaad4da25f523044f2034317e298435cca48abd53a",
      "source_url": "https://olls.info/crs/crs2026-title-39.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#CT.llc.base_tax_locator.corporation_business_tax_capital_base": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Rate, base, subtraction, apportionment, minimum and cap: § 12-219(a)(1).",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-219(a)(1) (2026 Supp.)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each company subject to the provisions of this part shall pay for the privilege of carrying on or doing business within the state, the larger of the tax, if any, imposed by section 12-214 and the tax calculated under this subsection. The tax calculated under this section shall be a tax of (A) three and one-tenth mills per dollar for income years commencing prior to January 1, 2024, (B) two and six-tenths mills per dollar for the income year commencing on or after January 1, 2024, and prior to January 1, 2025, (C) two and one-tenth mills per dollar for the income year commencing on or after January 1, 2025, and prior to January 1, 2026, (D) one and six-tenths mills per dollar for the income year commencing on or after January 1, 2026, and prior to January 1, 2027, (E) one and one-tenth mills per dollar for the income year commencing on or after January 1, 2027, and prior to January 1, 2028, and (F) zero mills per dollar for income years commencing on or after January 1, 2028, of the amount derived (i) by adding (I) the average value of the issued and outstanding capital stock, including treasury stock at par or face value, fractional shares, scrip certificates convertible into shares of stock and amounts received on subscriptions to capital stock, computed on the balances at the beginning and end of the taxable year or period, the average value of surplus and undivided profit computed on the balances at the beginning and end of the taxable year or period, and (II) the average value of all surplus reserves computed on the balances at the beginning and end of the taxable year or period, (ii) by subtracting from the sum so calculated (I) the average value of any deficit carried on the balance sheet computed on the balances at the beginning and end of the taxable year or period, and (II) the average value of any holdings of stock of private corporations including treasury stock shown on the balance sheet computed on the balances at the beginning and end of the taxable year or period, and (iii) by apportioning the remainder so derived between this and other states under the provisions of section 12-219a, provided in no event shall the tax so calculated exceed one million dollars or be less than two hundred fifty dollars.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687",
      "source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.base_tax_locator.corporation_business_tax_net_income": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Rate and imposition: § 12-214(a)(1); net-income deductions: § 12-217.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-214(a)(1) (2026 Supp.)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a)(1) Every mutual savings bank, savings and loan association and every company engaged in the business of carrying passengers for hire over the highways of this state in common carrier motor vehicles doing business in this state, and every other company carrying on, or having the right to carry on, business in this state, including a dissolved corporation which continues to conduct business, except those companies described in subdivision (2) of this subsection, shall pay, annually, a tax or excise upon its franchise for the privilege of carrying on or doing business, owning or leasing property within the state in a corporate capacity or as an unincorporated association taxable as a corporation for federal income tax purposes or maintaining an office within the state, such tax to be measured by the entire net income as herein defined received by such corporation or association from business transacted within the state during the income year and to be assessed for each income year commencing prior to January 1, 1995, at the rate of eleven and one-half per cent, for income years commencing on or after January 1, 1995, and prior to January 1, 1996, at the rate of eleven and one-quarter per cent, for income years commencing on or after January 1, 1996, and prior to January 1, 1997, at the rate of ten and three-fourths per cent, for income years commencing on or after January 1, 1997, and prior to January 1, 1998, at the rate of ten and one-half per cent, for income years commencing on or after January 1, 1998, and prior to January 1, 1999, at the rate of nine and one-half per cent, for income years commencing on or after January 1, 1999, and prior to January 1, 2000, at the rate of eight and one-half per cent, and for income years commencing on or after January 1, 2000, at the rate of seven and one-half per cent. The exemption of companies described in subparagraphs (G) and (H) of subdivision (2) of this subsection shall not be allowed with respect to any income year of any such company commencing on or after January 1, 1998, and any such company claiming such exemption for any income years commencing on or after January 1, 1985, but prior to January 1, 1998, shall be required to file a corporation business tax return in accordance with section 12-222 for each such income year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687",
      "source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Rate and tax base: § 12-699(c).",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-699(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax due under subsection (b) of this section shall be equal to six and ninety-nine-hundredths per cent multiplied by the tax base. The tax base shall be equal to the resident portion of unsourced income plus modified Connecticut source income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.does_not_reach.corporation_business_tax_capital_base": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Section 12-219a separately apportions investments other than private-corporation stock, plus cash, credits and other intangible assets.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-219a(a)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The average monthly value of all investments other than stock of private corporations, and all cash, credits and other intangible assets of the taxpayer shall be divided between (A) those having a tax situs within the state and (B) those having a tax situs without the state",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/09db866137339fa1c9e33a44d485f812c8a86b5b3fb5eb5eb6afbcf39751d02d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "09db866137339fa1c9e33a44d485f812c8a86b5b3fb5eb5eb6afbcf39751d02d",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_208.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#CT.llc.does_not_reach.corporation_business_tax_net_income": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-213(a)(27)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "“Passive investment company” means any corporation which is a related person to a financial service company, as defined in section 12-218b , or to an insurance company, as defined in section 12-218b , and (A) employs not less than five full-time equivalent employees in the state; (B) maintains an office in the state; and (C) confines its activities to the purchase, receipt, maintenance, management and sale of its intangible investments, and the collection and distribution of the income from such investments, including, but not limited to, interest and gains from the sale, transfer or assignment of such investments or from the foreclosure upon or sale, transfer or assignment of the collateral securing such investments. For purposes of this subdivision, “intangible investments” shall be limited to loans secured by real property, as defined in section 12-218b , including a line of credit which is a loan secured by real property and which permits future advances by the passive investment company; the collateral or an interest in the collateral that secured such loans if the sale of such collateral or interest is actively marketed by or on behalf of the passive investment company; and any short-term investment of cash held by the passive investment company which cash is reasonably necessary for the operations of such passive investment company",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/09db866137339fa1c9e33a44d485f812c8a86b5b3fb5eb5eb6afbcf39751d02d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "09db866137339fa1c9e33a44d485f812c8a86b5b3fb5eb5eb6afbcf39751d02d",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Affected business entity excludes a qualifying publicly traded partnership that agrees to file the described annual unitholder return.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-699(a)(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) “Affected business entity” means a partnership or an S corporation, but does not include a publicly-traded partnership, as defined in Section 7704(b) of the Internal Revenue Code, that has agreed to file an annual return pursuant to section 12-726 reporting the name, address, Social Security number or federal employer identification number and such other information required by the Commissioner of Revenue Services of each unitholder whose distributive share of partnership income derived from or connected with sources within this state was more than five hundred dollars",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.effective_period.corporation_business_tax_capital_base": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-219(a)(1)(A)-(F) (2026 Supp.)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax calculated under this section shall be a tax of (A) three and one-tenth mills per dollar for income years commencing prior to January 1, 2024, (B) two and six-tenths mills per dollar for the income year commencing on or after January 1, 2024, and prior to January 1, 2025, (C) two and one-tenth mills per dollar for the income year commencing on or after January 1, 2025, and prior to January 1, 2026, (D) one and six-tenths mills per dollar for the income year commencing on or after January 1, 2026, and prior to January 1, 2027, (E) one and one-tenth mills per dollar for the income year commencing on or after January 1, 2027, and prior to January 1, 2028, and (F) zero mills per dollar for income years commencing on or after January 1, 2028,",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687",
      "source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.effective_period.corporation_business_tax_net_income": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Section 12-214(a)(1) states the current net-income rate for income years beginning on or after January 1, 2000.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-214(a)(1) (2026 Supp.)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a)(1) Every mutual savings bank, savings and loan association and every company engaged in the business of carrying passengers for hire over the highways of this state in common carrier motor vehicles doing business in this state, and every other company carrying on, or having the right to carry on, business in this state, including a dissolved corporation which continues to conduct business, except those companies described in subdivision (2) of this subsection, shall pay, annually, a tax or excise upon its franchise for the privilege of carrying on or doing business, owning or leasing property within the state in a corporate capacity or as an unincorporated association taxable as a corporation for federal income tax purposes or maintaining an office within the state, such tax to be measured by the entire net income as herein defined received by such corporation or association from business transacted within the state during the income year and to be assessed for each income year commencing prior to January 1, 1995, at the rate of eleven and one-half per cent, for income years commencing on or after January 1, 1995, and prior to January 1, 1996, at the rate of eleven and one-quarter per cent, for income years commencing on or after January 1, 1996, and prior to January 1, 1997, at the rate of ten and three-fourths per cent, for income years commencing on or after January 1, 1997, and prior to January 1, 1998, at the rate of ten and one-half per cent, for income years commencing on or after January 1, 1998, and prior to January 1, 1999, at the rate of nine and one-half per cent, for income years commencing on or after January 1, 1999, and prior to January 1, 2000, at the rate of eight and one-half per cent, and for income years commencing on or after January 1, 2000, at the rate of seven and one-half per cent. The exemption of companies described in subparagraphs (G) and (H) of subdivision (2) of this subsection shall not be allowed with respect to any income year of any such company commencing on or after January 1, 1998, and any such company claiming such exemption for any income years commencing on or after January 1, 1985, but prior to January 1, 1998, shall be required to file a corporation business tax return in accordance with section 12-222 for each such income year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687",
      "source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The elective regime applies for taxable years beginning on or after January 1, 2024.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-699(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years commencing on or after January 1, 2024, an affected business entity that is required to file a return under the provisions of section 12-726 may elect to pay to the commissioner a tax as determined under this section. Any affected business entity making such election shall submit written notice of such election to the commissioner (1) not later than the due date or, if an extension of time to file has been requested and granted, the extended due date, of the return due from such entity, and (2) for each taxable year such entity makes the election under this subsection. Each affected business entity that has made the election under this subsection shall pay to the commissioner, on or before the fifteenth day of the third month following the close of each taxable year that such entity makes such election, a tax as determined under this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.filing_rule.corporation_business_tax_capital_base": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Each company subject to the tax must render the commissioner an annual return.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-222(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each company subject to the tax imposed under this part shall render to the commissioner an annual return, signed by one of its principal officers, on forms prescribed or furnished by the commissioner, stating specifically the name of the company and the location of its principal office, the state where organized and the date of organization, the names and locations of all subsidiaries, the amount of its paid-up capital and surplus at the end of the income year, the amount of its undivided profits and reserves at the end of such year, the par value of all indebtedness at the end of such year, the items of gross income received during such year, the deductions permitted by law, the interest and rental payments during such year, the dividend payments and changes in capital, surplus and undivided profits during such year, complete balance sheets at the beginning and end of such year or period and such other facts as the commissioner may require for the purpose of making any computation required by this part.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/09db866137339fa1c9e33a44d485f812c8a86b5b3fb5eb5eb6afbcf39751d02d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "09db866137339fa1c9e33a44d485f812c8a86b5b3fb5eb5eb6afbcf39751d02d",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.filing_rule.corporation_business_tax_net_income": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Each company subject to the tax must render the commissioner an annual return.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-222(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each company subject to the tax imposed under this part shall render to the commissioner an annual return, signed by one of its principal officers, on forms prescribed or furnished by the commissioner, stating specifically the name of the company and the location of its principal office, the state where organized and the date of organization, the names and locations of all subsidiaries, the amount of its paid-up capital and surplus at the end of the income year, the amount of its undivided profits and reserves at the end of such year, the par value of all indebtedness at the end of such year, the items of gross income received during such year, the deductions permitted by law, the interest and rental payments during such year, the dividend payments and changes in capital, surplus and undivided profits during such year, complete balance sheets at the beginning and end of such year or period and such other facts as the commissioner may require for the purpose of making any computation required by this part.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/09db866137339fa1c9e33a44d485f812c8a86b5b3fb5eb5eb6afbcf39751d02d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "09db866137339fa1c9e33a44d485f812c8a86b5b3fb5eb5eb6afbcf39751d02d",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-699(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years commencing on or after January 1, 2024, an affected business entity that is required to file a return under the provisions of section 12-726 may elect to pay to the commissioner a tax as determined under this section. Any affected business entity making such election shall submit written notice of such election to the commissioner (1) not later than the due date or, if an extension of time to file has been requested and granted, the extended due date, of the return due from such entity, and (2) for each taxable year such entity makes the election under this subsection. Each affected business entity that has made the election under this subsection shall pay to the commissioner, on or before the fifteenth day of the third month following the close of each taxable year that such entity makes such election, a tax as determined under this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.tax_regime.corporation_business_tax_capital_base": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A company subject to chapter 208 pays the larger of the § 12-214 tax and the capital-base calculation in § 12-219(a).",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-219(a)(1) (2026 Supp.)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each company subject to the provisions of this part shall pay for the privilege of carrying on or doing business within the state, the larger of the tax, if any, imposed by section 12-214 and the tax calculated under this subsection. The tax calculated under this section shall be a tax of (A) three and one-tenth mills per dollar for income years commencing prior to January 1, 2024, (B) two and six-tenths mills per dollar for the income year commencing on or after January 1, 2024, and prior to January 1, 2025, (C) two and one-tenth mills per dollar for the income year commencing on or after January 1, 2025, and prior to January 1, 2026, (D) one and six-tenths mills per dollar for the income year commencing on or after January 1, 2026, and prior to January 1, 2027, (E) one and one-tenth mills per dollar for the income year commencing on or after January 1, 2027, and prior to January 1, 2028, and (F) zero mills per dollar for income years commencing on or after January 1, 2028, of the amount derived (i) by adding (I) the average value of the issued and outstanding capital stock, including treasury stock at par or face value, fractional shares, scrip certificates convertible into shares of stock and amounts received on subscriptions to capital stock, computed on the balances at the beginning and end of the taxable year or period, the average value of surplus and undivided profit computed on the balances at the beginning and end of the taxable year or period, and (II) the average value of all surplus reserves computed on the balances at the beginning and end of the taxable year or period, (ii) by subtracting from the sum so calculated (I) the average value of any deficit carried on the balance sheet computed on the balances at the beginning and end of the taxable year or period, and (II) the average value of any holdings of stock of private corporations including treasury stock shown on the balance sheet computed on the balances at the beginning and end of the taxable year or period, and (iii) by apportioning the remainder so derived between this and other states under the provisions of section 12-219a, provided in no event shall the tax so calculated exceed one million dollars or be less than two hundred fifty dollars.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687",
      "source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.tax_regime.corporation_business_tax_net_income": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-214(a)(1) (2026 Supp.)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a)(1) Every mutual savings bank, savings and loan association and every company engaged in the business of carrying passengers for hire over the highways of this state in common carrier motor vehicles doing business in this state, and every other company carrying on, or having the right to carry on, business in this state, including a dissolved corporation which continues to conduct business, except those companies described in subdivision (2) of this subsection, shall pay, annually, a tax or excise upon its franchise for the privilege of carrying on or doing business, owning or leasing property within the state in a corporate capacity or as an unincorporated association taxable as a corporation for federal income tax purposes or maintaining an office within the state, such tax to be measured by the entire net income as herein defined received by such corporation or association from business transacted within the state during the income year and to be assessed for each income year commencing prior to January 1, 1995, at the rate of eleven and one-half per cent, for income years commencing on or after January 1, 1995, and prior to January 1, 1996, at the rate of eleven and one-quarter per cent, for income years commencing on or after January 1, 1996, and prior to January 1, 1997, at the rate of ten and three-fourths per cent, for income years commencing on or after January 1, 1997, and prior to January 1, 1998, at the rate of ten and one-half per cent, for income years commencing on or after January 1, 1998, and prior to January 1, 1999, at the rate of nine and one-half per cent, for income years commencing on or after January 1, 1999, and prior to January 1, 2000, at the rate of eight and one-half per cent, and for income years commencing on or after January 1, 2000, at the rate of seven and one-half per cent. The exemption of companies described in subparagraphs (G) and (H) of subdivision (2) of this subsection shall not be allowed with respect to any income year of any such company commencing on or after January 1, 1998, and any such company claiming such exemption for any income years commencing on or after January 1, 1985, but prior to January 1, 1998, shall be required to file a corporation business tax return in accordance with section 12-222 for each such income year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687",
      "source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-699(b)-(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years commencing on or after January 1, 2024, an affected business entity that is required to file a return under the provisions of section 12-726 may elect to pay to the commissioner a tax as determined under this section. Any affected business entity making such election shall submit written notice of such election to the commissioner (1) not later than the due date or, if an extension of time to file has been requested and granted, the extended due date, of the return due from such entity, and (2) for each taxable year such entity makes the election under this subsection. Each affected business entity that has made the election under this subsection shall pay to the commissioner, on or before the fifteenth day of the third month following the close of each taxable year that such entity makes such election, a tax as determined under this section. (c) The tax due under subsection (b) of this section shall be equal to six and ninety-nine-hundredths per cent multiplied by the tax base. The tax base shall be equal to the resident portion of unsourced income plus modified Connecticut source income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.treatment.corporation_business_tax_capital_base": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Private-corporation stock holdings are subtracted from the capital-base calculation under § 12-219(a)(1)(ii).",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-219(a)(1)(ii) (2026 Supp.)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "by subtracting from the sum so calculated (I) the average value of any deficit carried on the balance sheet computed on the balances at the beginning and end of the taxable year or period, and (II) the average value of any holdings of stock of private corporations including treasury stock shown on the balance sheet computed on the balances at the beginning and end of the taxable year or period",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687",
      "source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.treatment.corporation_business_tax_net_income": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Dividend income receives the quoted deduction in computing net income, with a partial limitation for certain below-20% domestic-corporation holdings.",
      "fetch_event_id": null,
      "pinpoint": "Conn. Gen. Stat. § 12-217(a)(1)(D) (2026 Supp.)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(D) Additionally, in the case of all taxpayers, all dividends as defined in the Internal Revenue Code effective and in force on the last day of the income year not otherwise deducted from gross income, including dividends received from a DISC or former DISC as defined in Section 992 of the Internal Revenue Code and dividends deemed to have been distributed by a DISC or former DISC as provided in Section 995 of said Internal Revenue Code, other than thirty per cent of dividends received from a domestic corporation in which the taxpayer owns less than twenty per cent of the total voting power and value of the stock of such corporation",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4af9238b503dce8764ac935bb5f3ead34b133108112f532b6675e99e2dcc2687",
      "source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#CT.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "No holding-entity or passive-income carve-out was located in chapter 228z; the regime is elective.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/CT/snapshots/c50/CT/CT/ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ee56d9f6664be45430c5400eb6840f7d6478d3cb5dd176af2163fe874dff5a88",
      "source_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.base_tax_locator.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "D.C. Code § 47-1807.02(b)",
          "quote": "Corporations or financial institutions including International Banking Facilities shall not be exempt from the minimum tax payable under this section even if the business or source income is exempt under other provisions of this chapter.",
          "role": "minimum-tax locator",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
          "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
          "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate tax rate and minimum-tax provisions are located at D.C. Code § 47-1807.02(a)-(b).",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1807.02(a)-(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning after December 31, 2017, a tax at the rate of 8.25% upon the taxable income of every corporation, whether domestic or foreign.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.base_tax_locator.unincorporated_business_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The unincorporated-business tax rate and minimum-tax provisions are located at D.C. Code § 47-1808.03(a)-(b).",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1808.03(a)-(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning after December 31, 2017, a tax at the rate of 8.25% upon the taxable income of every unincorporated business, whether domestic or foreign.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.does_not_reach.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1810.01(a)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "provided, however, that, in the case of any corporation, the amount received as dividends from a corporation which is subject to taxation under this chapter or under Chapter 26 of this title, and, in the case of a corporation not engaged in carrying on any trade or business within the District, interest received by it from a corporation which is subject to taxation under this chapter or under Chapter 26 of this title shall not be considered as income from sources within the District for purposes of this chapter;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.does_not_reach.unincorporated_business_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The own-account exclusion does not cover dealer inventory, ordinary-course lender debt, or non-publicly-traded REIT stock or partnership interests.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1808.01(6)(A)-(C)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "provided, that this paragraph shall not apply to: (A) A taxpayer that holds property, or maintains positions, as stock in trade, inventory, or for sale to customers in the ordinary course of the taxpayer’s trade or business; (B) A taxpayer that acquires debt instruments in the ordinary course of the taxpayer’s trade or business for funds loaned or services rendered; or (C) A taxpayer that holds any of the following that is not traded on an established securities market: (i) Stock in a real estate investment trust; or (ii) A partnership interest.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.effective_period.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current corporate levy provision applies for taxable years beginning after December 31, 2017.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1807.02(a)(8)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning after December 31, 2017, a tax at the rate of 8.25% upon the taxable income of every corporation, whether domestic or foreign.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.effective_period.unincorporated_business_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The own-account exclusion applies for tax years beginning after December 31, 2014.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1808.01(6)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For tax years beginning after December 31, 2014, a trade or business that arises solely by reason of the purchase, holding, or sale of, or the entering, maintaining, or terminating of positions in, stocks, securities, or commodities for the taxpayer’s own account;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.filing_rule.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1805.02(5)(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every corporation or financial institution engaging in or carrying on any trade or business within the District or receiving income from sources within the District within the meaning of §§ 47-1810.01 to 47-1810.03, even if the business or source income is exempt under other provisions of this chapter.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.filing_rule.unincorporated_business_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Chapter 18 does not separately state a filing rule for an activity excluded from the unincorporated-business definition by the own-account carve-out.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code Title 47, Chapter 18, complete search",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.tax_regime.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate franchise tax applies to every domestic or foreign corporation for current taxable years.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1807.02(a)(8)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning after December 31, 2017, a tax at the rate of 8.25% upon the taxable income of every corporation, whether domestic or foreign.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.tax_regime.unincorporated_business_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The unincorporated-business franchise tax applies to every domestic or foreign unincorporated business for current taxable years.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1808.03(a)(8)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning after December 31, 2017, a tax at the rate of 8.25% upon the taxable income of every unincorporated business, whether domestic or foreign.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DC.llc.treatment.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "D.C. Code § 47-1807.02(b)",
          "quote": "Corporations or financial institutions including International Banking Facilities shall not be exempt from the minimum tax payable under this section even if the business or source income is exempt under other provisions of this chapter.",
          "role": "minimum-tax rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
          "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
          "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1810.01(a)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "provided, however, that, in the case of any corporation, the amount received as dividends from a corporation which is subject to taxation under this chapter or under Chapter 26 of this title, and, in the case of a corporation not engaged in carrying on any trade or business within the District, interest received by it from a corporation which is subject to taxation under this chapter or under Chapter 26 of this title shall not be considered as income from sources within the District for purposes of this chapter;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#DC.llc.treatment.unincorporated_business_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A qualifying own-account holding activity is excluded from the statutory definition of an unincorporated business, subject to the stated exceptions.",
      "fetch_event_id": null,
      "pinpoint": "D.C. Code § 47-1808.01(6)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For tax years beginning after December 31, 2014, a trade or business that arises solely by reason of the purchase, holding, or sale of, or the entering, maintaining, or terminating of positions in, stocks, securities, or commodities for the taxpayer’s own account;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DC/snapshots/c50/DC/6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f2277819a455467ffcc3c92b03d602b796077c4b4babd289120be2776660d26",
      "source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#DE.llc.base_tax_locator.affiliated_finance_company_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The tax table is in 30 Del. C. § 6303(a), and the capital base it is measured by is defined in § 6303(b).",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 6303; Title 30, Chapter 63 capture, § 6303",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax payable by an affiliated finance company shall be in accordance with the following table",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427",
      "source_url": "https://delcode.delaware.gov/title30/c063/index.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#DE.llc.base_tax_locator.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The rate is set in 30 Del. C. § 1902(a); taxable income is computed, allocated and apportioned under 30 Del. C. § 1903.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 1902(a); Title 30, Chapter 19 capture, § 1902",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every domestic or foreign corporation that is not exempt under subsection (b) of this section shall annually pay a tax of 8.7 percent on its taxable income, computed in accordance with § 1903 of this title, which shall be deemed to be its net income derived from business activities carried on and property located within the State during the income year.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f",
      "source_url": "https://delcode.delaware.gov/title30/c019/index.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#DE.llc.base_tax_locator.headquarters_management_corporation_tax": {
      "additional_sources": [
        {
          "pinpoint": "30 Del. C. § 2301(a)(25), (f); Title 30, Chapter 23 capture",
          "quote": "(25) Headquarters Management Corporation, $5,000; provided, however, that in the case of any affiliated group, as defined in § 6401(1) of this title, only 1 member of such affiliated group that is a Headquarters Management Corporation shall be liable for a $5,000 annual license tax under this paragraph (a)(25), and each other member of such affiliated group that is a Headquarters Management Corporation shall pay a license tax of $500. For purposes of this paragraph (a)(25), “Headquarters Management Corporation” has the meaning set forth in § 6401(5) of this title. […] (f) Paragraphs (a)(5), (8), (9), (12), (13), (17), (18), (20)-(25), and (28) of this section shall be exempt from the additional license fee imposed by subsection (d) of this section.",
          "role": "license_tax_locator",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e.html",
          "source_sha256": "19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e",
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The tax is set in 30 Del. C. § 6402 and its base computed under § 6403; the separate Headquarters Management Corporation license tax is in § 2301(a)(25), with § 2301(f).",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 6402; Title 30, Chapter 64 capture, § 6402",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every Headquarters Management Corporation shall annually pay a tax in lieu of the taxes imposed under Chapter 19 of this title",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3",
      "source_url": "https://delcode.delaware.gov/title30/c064/index.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#DE.llc.base_tax_locator.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The annual tax amounts are set in 6 Del. C. § 18-1107(b), with the due date and interest in § 18-1107(c) and the late-payment penalty in § 18-1107(e).",
      "fetch_event_id": null,
      "pinpoint": "6 Del. C. § 18-1107(b); Title 6, Chapter 18, Subchapter XI capture, § 18-1107",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every domestic limited liability company and every foreign limited liability company registered to do business in the State of Delaware shall pay an annual tax, for the use of the State of Delaware, in the amount of $400.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
      "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.base_tax_locator.occupational_license_gross_receipts_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "License tax amounts are in 30 Del. C. § 2301(a) and (b); the gross receipts license fee rate and its deductions are in § 2301(d).",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 2301(d)(1); Title 30, Chapter 23 capture, § 2301",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(d) (1) In addition to the license fee required by subsections (a) and (b) of this section, every person shall also pay a license fee at the rate of 0.3983% of the aggregate gross receipts paid to such person attributable to activities licensable under this chapter",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e",
      "source_url": "https://delcode.delaware.gov/title30/c023/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.does_not_reach.affiliated_finance_company_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. §§ 6301(2), 6305; Title 30, Chapter 63 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) “Affiliated finance company” means a corporation substantially all of whose activity within this State is limited to the issuance of commercial paper or other debt obligations and use of the proceeds to make loans to 1 or more of its affiliated corporations or to purchase receivables from 1 or more of its affiliated corporations. […] all affiliated finance companies being taxed in accordance with this chapter shall be exempt from any occupational license taxes imposed by Part III of this title.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427",
      "source_url": "https://delcode.delaware.gov/title30/c063/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.does_not_reach.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 1902(b)(8); Title 30, Chapter 19 capture, § 1902",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(8) Corporations whose activities within this State are confined to the maintenance and management of their intangible investments or of the intangible investments of corporations or statutory trusts or business trusts registered as investment companies under the Investment Company Act of 1940, as amended (15 U.S.C. 80a-1 et seq.) and the collection and distribution of the income from such investments or from tangible property physically located outside this State.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f",
      "source_url": "https://delcode.delaware.gov/title30/c019/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.does_not_reach.headquarters_management_corporation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The election ends if the taxpayer revokes it or fails to limit its Delaware activities to headquarters services or investment activities.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 6404(b); Title 30, Chapter 64 capture, § 6404",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An election under this section shall remain in effect until terminated by revocation by the taxpayer or the taxpayer’s failing to limit its activities in this State to headquarters services or investment activities.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3",
      "source_url": "https://delcode.delaware.gov/title30/c064/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.does_not_reach.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "6 Del. C. ch. 18, Subchapters I-XII (§§ 18-101 to 18-1208), full text; operative tax section § 18-1107 in the Subchapter XI capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
      "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.does_not_reach.occupational_license_gross_receipts_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 2301(o), (a)(6), (c)(3), (e)(4); Title 30, Chapter 23 capture, § 2301",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "provided, however, this exemption shall not apply to those activities of the foregoing persons which are required to be licensed under paragraph (6) of subsection (a) of this section. […] (6) Commercial lessor, $75. “Commercial lessor” includes every person who, as lessor or sublessor, receives rental income pursuant to any agreement transferring a title interest or possessory interest in real property located in this State under a lease of a commercial unit for any term.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e",
      "source_url": "https://delcode.delaware.gov/title30/c023/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.effective_period.affiliated_finance_company_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The license requirement applies to carrying on business as an affiliated finance company after May 1, 1981 (30 Del. C. § 6302).",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 6302; Title 30, Chapter 63 capture, § 6302",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "No corporation shall carry on business as an affiliated finance company after May 1, 1981, without an unexpired license issued by the Secretary of Finance authorizing the conduct of such business.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427",
      "source_url": "https://delcode.delaware.gov/title30/c063/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.effective_period.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Chapter 19 states the corporation income tax was first effective for income earned after December 31, 1957 (30 Del. C. § 1907).",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 1907; Title 30, Chapter 19 capture, § 1907",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax shall be first effective with respect to income earned subsequent to December 31, 1957.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f",
      "source_url": "https://delcode.delaware.gov/title30/c019/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.effective_period.headquarters_management_corporation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Chapter 64 states no effective or sunset date for the Headquarters Management Corporation tax; a full-text search of the chapter found none.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. ch. 64, §§ 6401-6407, full text",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3",
      "source_url": "https://delcode.delaware.gov/title30/c064/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.effective_period.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "6 Del. C. ch. 18, Subchapters I-XII (§§ 18-101 to 18-1208), full text; operative tax section § 18-1107 in the Subchapter XI capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
      "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.effective_period.occupational_license_gross_receipts_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. ch. 21 (§§ 2101-2126) and ch. 23 (§§ 2301-2306), full text",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e",
      "source_url": "https://delcode.delaware.gov/title30/c023/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.filing_rule.affiliated_finance_company_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. §§ 6302, 6304; Title 30, Chapter 63 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The license shall be issued by the Secretary of Finance for each calendar year. Upon payment of the tax imposed by § 6303 of this title, the Secretary shall issue the license with respect to each calendar year. […] The tax imposed by § 6303 of this title shall be due and payable in a single installment on or before April 30 of the calendar year with respect to which the license is issued or as soon thereafter as the corporation shall commence operations as an affiliated finance company as shown on its certified financial statements for its fiscal year ending with or within the immediately preceding calendar year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427",
      "source_url": "https://delcode.delaware.gov/title30/c063/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.filing_rule.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Division of Revenue, Corporate Income Tax FAQs, \"What are the corporate income tax filing requirements for a holding company?\"",
          "quote": "Corporations whose activities in Delaware are limited to the maintenance and management of their intangible investments may be exempt under Section 1902(b)(8), Title 30, Delaware Code . Corporations may obtain a specific ruling from the Division of Revenue by submitting an Application of Exemption, Form CIT-EXM, describing their operations and stating the grounds for the exemption under Section 1902(b)(8). Please note, Section 1904(f), Title 30, Delaware Code, requires that corporations exempt under Section 1902(b)(8) file an Annual Information Return (Form CIT-HIC) reporting sources of income and services provided within and without Delaware.",
          "role": "agency_guidance",
          "snapshot_path": "rigs/entity-research/corp-lp/snapshots/DE/cb28842fb5f3da021d164885291c24dcefba1d27cea065e4e4325cade77949bf.html",
          "source_sha256": "cb28842fb5f3da021d164885291c24dcefba1d27cea065e4e4325cade77949bf",
          "source_url": "https://revenue.delaware.gov/frequently-asked-questions/corporate-income-tax-faqs/"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 1904(e)-(f); Title 30, Chapter 19 capture, § 1904",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(e) Every domestic or foreign corporation not exempt under § 1902 of this title shall file an annual tentative return and an annual final return regardless of the amount of its estimated tax liability, its gross income or its taxable income. (f) The Secretary may require every corporation exempt from taxation under § 1902(b) of this title to file an information return for each taxable year setting forth the items of gross income and deductions and such other information as the Secretary, by forms or regulation, may prescribe.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f",
      "source_url": "https://delcode.delaware.gov/title30/c019/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.filing_rule.headquarters_management_corporation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The election is filed with the Headquarters Management Corporation license application, and annual tentative and final returns are required regardless of liability or income.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 6404(a), (c); Title 30, Chapter 64 capture, § 6404",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Election. — Every Headquarters Management Corporation desiring to be certified under this chapter shall file an election with its application for a Headquarters Management Corporation license. […] (c) Returns. — Every Headquarters Management Corporation shall file an annual tentative return and an annual final return regardless of the amount of its estimated tax liability, its gross income or its taxable income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3",
      "source_url": "https://delcode.delaware.gov/title30/c064/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.filing_rule.llc_annual_tax": {
      "additional_sources": [
        {
          "pinpoint": "6 Del. C. § 18-1107(c)-(d); Title 6, Chapter 18, Subchapter XI capture, § 18-1107",
          "quote": "The annual tax for a domestic limited liability company shall be due and payable on the first day of June following the close of the calendar year or upon the cancellation of a certificate of formation. […] The Secretary of State shall, at least 60 days prior to June 1 of each year, cause to be mailed to each domestic limited liability company and each registered series thereof and each foreign limited liability company required to comply with the provisions of this section in care of its registered agent in the State of Delaware an annual statement for the tax to be paid hereunder.",
          "role": "statutory_due_date",
          "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
          "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
          "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Division of Corporations, LLC/LP/GP Franchise Tax Instructions page, \"LLC/Partnership Tax Information\"",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "All Domestic and Foreign Limited Liability Companies, Limited Partnerships, and General Partnerships formed or registered in Delaware are required to pay an annual tax of $400.00. There is no requirement to file an Annual Report. The annual taxes for the prior year are due on or before June 1st.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/a516ce9687945274d4f927f999e4aa21233a50d8b0d316ec4e9c41865f446d8a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a516ce9687945274d4f927f999e4aa21233a50d8b0d316ec4e9c41865f446d8a",
      "source_url": "https://corp.delaware.gov/alt-entitytaxinstructions/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.filing_rule.occupational_license_gross_receipts_tax": {
      "additional_sources": [
        {
          "pinpoint": "30 Del. C. § 2123; Title 30, Chapter 21 capture",
          "quote": "The Director may, by regulation, to include by means of instructions accompanying returns, waive quarterly filing of returns relative to taxes on gross receipts in the case of taxpayers who have had no taxable gross receipts within the quarter. In no event shall taxpayers required to report gross receipts be permitted to file any less frequently than annually.",
          "role": "general_filing_rule_not_holding_specific",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/1af86eac92ccf9fe0c78c30e82b8efffcbad849c8f4e003a1ea21cbe33ca44a7.html",
          "source_sha256": "1af86eac92ccf9fe0c78c30e82b8efffcbad849c8f4e003a1ea21cbe33ca44a7",
          "source_url": "https://delcode.delaware.gov/title30/c021/index.html"
        },
        {
          "pinpoint": "Division of Revenue, Business Licenses FAQs, \"Who needs to obtain a Delaware business license in the State of Delaware?\"",
          "quote": "Any person or entity conducting a trade or business in the State of Delaware is required to obtain a Delaware business license from the Delaware Division of Revenue.",
          "role": "agency_guidance_not_holding_specific",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/53e0cc9a5a43ae11a858a6874ec55317d54855d3b888582f3c0db58418b9bb55.html",
          "source_sha256": "53e0cc9a5a43ae11a858a6874ec55317d54855d3b888582f3c0db58418b9bb55",
          "source_url": "https://revenue.delaware.gov/frequently-asked-questions/business-licenses-faqs/"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. ch. 21 (§§ 2101-2126) and ch. 23 (§§ 2301-2306), full text",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e",
      "source_url": "https://delcode.delaware.gov/title30/c023/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.tax_regime.affiliated_finance_company_tax": {
      "additional_sources": [
        {
          "pinpoint": "6 Del. C. § 18-1107(a); Title 6, Chapter 18, Subchapter XI capture, § 18-1107",
          "quote": "For purposes of any tax imposed by the State of Delaware or any instrumentality, agency or political subdivision of the State of Delaware, a domestic limited liability company or a foreign limited liability company qualified to do business in the State of Delaware shall be classified as a partnership unless classified otherwise for federal income tax purposes, in which case the domestic or foreign limited liability company shall be classified in the same manner as it is classified for federal income tax purposes.",
          "role": "llc_tax_classification",
          "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
          "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
          "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. §§ 6302, 6303(a); Title 30, Chapter 63 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "No corporation shall carry on business as an affiliated finance company after May 1, 1981, without an unexpired license issued by the Secretary of Finance authorizing the conduct of such business. […] (a) The tax payable by an affiliated finance company shall be in accordance with the following table: If the capital base is: The annual license fee shall be: $0 to $99,999,999.99 $10,000 $100,000,000 to $224,999,999.99 $15,000 $225,000,000 to $749,999,999.99 $25,000 Over $750,000,000 $50,000",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427",
      "source_url": "https://delcode.delaware.gov/title30/c063/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.tax_regime.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "6 Del. C. § 18-1107(a); Title 6, Chapter 18, Subchapter XI capture, § 18-1107",
          "quote": "For purposes of any tax imposed by the State of Delaware or any instrumentality, agency or political subdivision of the State of Delaware, a domestic limited liability company or a foreign limited liability company qualified to do business in the State of Delaware shall be classified as a partnership unless classified otherwise for federal income tax purposes, in which case the domestic or foreign limited liability company shall be classified in the same manner as it is classified for federal income tax purposes.",
          "role": "llc_tax_classification",
          "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
          "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
          "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html"
        },
        {
          "pinpoint": "30 Del. C. § 1621(a); Title 30, Chapter 16, Subchapter II capture",
          "quote": "A pass-through entity as such shall not be subject to the income tax imposed by Chapter 11 or Chapter 19 of this title.",
          "role": "pass_through_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/ed7203fb5b975c5a7c39fd56ad153c2a3d9731454aac5abf783dfe0bb7f79b2b.html",
          "source_sha256": "ed7203fb5b975c5a7c39fd56ad153c2a3d9731454aac5abf783dfe0bb7f79b2b",
          "source_url": "https://delcode.delaware.gov/title30/c016/sc02/index.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 1902(a); Title 30, Chapter 19 capture, § 1902",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every domestic or foreign corporation that is not exempt under subsection (b) of this section shall annually pay a tax of 8.7 percent on its taxable income, computed in accordance with § 1903 of this title, which shall be deemed to be its net income derived from business activities carried on and property located within the State during the income year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f",
      "source_url": "https://delcode.delaware.gov/title30/c019/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.tax_regime.headquarters_management_corporation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "A certified Headquarters Management Corporation pays an annual tax in lieu of the Chapter 19 corporation income tax (30 Del. C. § 6402).",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 6402; Title 30, Chapter 64 capture, § 6402",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every Headquarters Management Corporation shall annually pay a tax in lieu of the taxes imposed under Chapter 19 of this title equal to the greater of: (1) Eight and seven tenths percent of its Headquarters Management Corporation taxable income; or (2) Five thousand dollars.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3",
      "source_url": "https://delcode.delaware.gov/title30/c064/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.tax_regime.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "6 Del. C. § 18-1107(b); Title 6, Chapter 18, Subchapter XI capture, § 18-1107",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every domestic limited liability company and every foreign limited liability company registered to do business in the State of Delaware shall pay an annual tax, for the use of the State of Delaware, in the amount of $400. There shall be paid by or on behalf of each registered series of a domestic limited liability company an annual tax, for use of the State of Delaware, in the amount of $100 per registered series.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
      "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.tax_regime.occupational_license_gross_receipts_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 2301(a), (b), (d)(1); Title 30, Chapter 23 capture, § 2301",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) “Persons” as defined in § 2701 of this title engaged in the occupations listed and defined in this section shall pay annual license taxes at the rates specified below. […] (b) Upon every person engaging or continuing to engage in any service industry, business, calling or profession not otherwise specifically licensed and taxed under subsection (a) of this section, there is hereby levied and there shall be collected an annual general service license fee of $75. […] (d) (1) In addition to the license fee required by subsections (a) and (b) of this section, every person shall also pay a license fee at the rate of 0.3983% of the aggregate gross receipts paid to such person attributable to activities licensable under this chapter",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e",
      "source_url": "https://delcode.delaware.gov/title30/c023/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.treatment.affiliated_finance_company_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. §§ 6303, 6305; Title 30, Chapter 63 capture",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) The tax payable by an affiliated finance company shall be in accordance with the following table: If the capital base is: The annual license fee shall be: $0 to $99,999,999.99 $10,000 $100,000,000 to $224,999,999.99 $15,000 $225,000,000 to $749,999,999.99 $25,000 Over $750,000,000 $50,000 […] (b) The “capital base” of an affiliated finance company shall consist of its capital, surplus and retained earnings, or equivalent accounting terms, as set forth in the company’s certified financial statements. […] Notwithstanding this title, all affiliated finance companies being taxed in accordance with this chapter shall be exempt from any occupational license taxes imposed by Part III of this title.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a951a14aa84626796995a13d256a746471b5688184c5549e17100b102995a427",
      "source_url": "https://delcode.delaware.gov/title30/c063/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.treatment.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "6 Del. C. § 18-1107(a); Title 6, Chapter 18, Subchapter XI capture, § 18-1107",
          "quote": "For purposes of any tax imposed by the State of Delaware or any instrumentality, agency or political subdivision of the State of Delaware, a domestic limited liability company or a foreign limited liability company qualified to do business in the State of Delaware shall be classified as a partnership unless classified otherwise for federal income tax purposes, in which case the domestic or foreign limited liability company shall be classified in the same manner as it is classified for federal income tax purposes.",
          "role": "llc_tax_classification",
          "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
          "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
          "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 1902(b)(8); Title 30, Chapter 19 capture, § 1902",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) The following corporations shall be exempt from taxation under this chapter: […] (8) Corporations whose activities within this State are confined to the maintenance and management of their intangible investments",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "73dd7609e7b60734f6396776951d5ef2217a8adb827921b02322e37ebef79d2f",
      "source_url": "https://delcode.delaware.gov/title30/c019/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.treatment.headquarters_management_corporation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 6402; Title 30, Chapter 64 capture, § 6402",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every Headquarters Management Corporation shall annually pay a tax in lieu of the taxes imposed under Chapter 19 of this title equal to the greater of: (1) Eight and seven tenths percent of its Headquarters Management Corporation taxable income; or (2) Five thousand dollars.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1fc2cdb0efb8cec4bebda01a1efaffb6dc4484f3c2a9ef998462c415f78200b3",
      "source_url": "https://delcode.delaware.gov/title30/c064/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.treatment.llc_annual_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The annual tax reaches every domestic LLC and every registered foreign LLC; the LLC Act states no exception for holding or passive LLCs.",
      "fetch_event_id": null,
      "pinpoint": "6 Del. C. § 18-1107(b); Title 6, Chapter 18, Subchapter XI capture, § 18-1107",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every domestic limited liability company and every foreign limited liability company registered to do business in the State of Delaware shall pay an annual tax, for the use of the State of Delaware",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
      "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#DE.llc.treatment.occupational_license_gross_receipts_tax": {
      "additional_sources": [
        {
          "pinpoint": "6 Del. C. § 18-1107(a); Title 6, Chapter 18, Subchapter XI capture, § 18-1107",
          "quote": "For purposes of any tax imposed by the State of Delaware or any instrumentality, agency or political subdivision of the State of Delaware, a domestic limited liability company or a foreign limited liability company qualified to do business in the State of Delaware shall be classified as a partnership unless classified otherwise for federal income tax purposes, in which case the domestic or foreign limited liability company shall be classified in the same manner as it is classified for federal income tax purposes.",
          "role": "llc_tax_classification",
          "snapshot_path": "rigs/entity-research/nonprofit/snapshots/DE/fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd.html",
          "source_sha256": "fe394ea173e7904410b1ccbb80213561cd958e38e31c2f15c9da42d874342ecd",
          "source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html"
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "§ 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.",
      "fetch_event_id": null,
      "pinpoint": "30 Del. C. § 2301(o), (c)(3), (e)(4); Title 30, Chapter 23 capture, § 2301",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(o) Banks, corporations described in § 1902(b)(8) of this title, […] are exempt from payment of fees as set forth in subsections (b) and (d) of this section; provided, however, this exemption shall not apply to those activities of the foregoing persons which are required to be licensed under paragraph (6) of subsection (a) of this section.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/DE/snapshots/c50/DE/19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e.html",
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      "source_class": "S1",
      "source_sha256": "19f8160b2d2bf3fd99d2d98819ba397fe3829c3bc83bae1ea09beab5dca4cd4e",
      "source_url": "https://delcode.delaware.gov/title30/c023/index.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#FL.llc.base_tax_locator.corporate_income_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Fla. Stat. § 220.12",
          "quote": "For purposes of this code, a taxpayer’s net income for a taxable year shall be its adjusted federal income, or that share of its adjusted federal income for such year which is apportioned to this state under s. 220.15, plus nonbusiness income allocated to this state pursuant to s. 220.16, less the exemption allowed by s. 220.14.",
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          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
        },
        {
          "pinpoint": "Fla. Stat. § 220.14",
          "quote": "(1) In computing a taxpayer’s liability for tax under this code, there shall be exempt from the tax $50,000 of net income as defined in s. 220.12 or such lesser amount as will, without increasing the taxpayer’s federal income tax liability, provide the state with an amount under this code which is equal to the maximum federal income tax credit which may be available from time to time under federal law. (2) In the case of a taxable year for a period of less than 12 months, the exemption allowed by this section shall be prorated on the basis of the number of days in such year to 365. (3) Only one exemption shall be allowed to taxpayers filing a consolidated return under this code. (4) Notwithstanding any other provision of this code, not more than one exemption under this section may be allowed to the Florida members of a controlled group of corporations, as defined in s. 1563 of the Internal Revenue Code with respect to taxable years ending on or after December 31, 1970, filing separate returns under this code. The exemption described in this section shall be divided equally among such Florida members of the group, unless all of such members consent, at such time and in such manner as the department shall by regulation prescribe, to an apportionment plan providing for an unequal allocation of such exemption.",
          "role": "base_exemption",
          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
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      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The imposition, net-income base, adjusted-federal-income rules, and exemption are located at Florida Statutes §§ 220.11 through 220.14.",
      "fetch_event_id": null,
      "pinpoint": "Fla. Stat. § 220.11(2)",
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      "quote": "(2)(a) The tax imposed by this section shall be an amount equal to 5 1 / 2 percent of the taxpayer’s net income for the taxable year, except as provided in paragraph (b). (b) The tax rate imposed in paragraph (a) shall be adjusted as provided in s. 220.1105.",
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      "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
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      "source_class": "S1",
      "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
      "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#FL.llc.does_not_reach.corporate_income_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Fla. Stat. § 220.02(1)",
          "quote": "(1) It is the intent of the Legislature in enacting this code to impose a tax upon all corporations, organizations, associations, and other artificial entities which derive from this state or from any other jurisdiction permanent and inherent attributes not inherent in or available to natural persons, such as perpetual life, transferable ownership represented by shares or certificates, and limited liability for all owners. It is intended that any limited liability company that is classified as a partnership for federal income tax purposes and is defined in and organized pursuant to chapter 605 or qualified to do business in this state as a foreign limited liability company not be subject to the tax imposed by this code. It is the intent of the Legislature to subject such corporations and other entities to taxation hereunder for the privilege of conducting business, deriving income, or existing within this state. This code is not intended to tax, and shall not be construed so as to tax, any natural person who engages in a trade, business, or profession in this state under his or her own or any fictitious name, whether individually as a proprietorship or in partnership with others, or as a member or a manager of a limited liability company classified as a partnership for federal income tax purposes; any estate of a decedent or incompetent; or any testamentary trust. However, a corporation or other taxable entity which is or which becomes partners with one or more natural persons shall not, merely by reason of being a partner, exclude from its net income subject to tax its respective share of partnership net income. This statement of intent shall be given preeminent consideration in any construction or interpretation of this code in order to avoid any conflict between this code and the mandate in s. 5, Art. VII of the State Constitution that no income tax be levied upon natural persons who are residents and citizens of this state.",
          "role": "partnership_classified_llc_exclusion",
          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Fla. Stat. § 220.03(1)(r)",
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      "quote": "(r) “Nonbusiness income” means rents and royalties from real or tangible personal property, capital gains, interest, dividends, and patent and copyright royalties, to the extent that they do not arise from transactions and activities in the regular course of the taxpayer’s trade or business. The term “nonbusiness income” does not include income from tangible and intangible property if the acquisition, management, and disposition of the property constitute integral parts of the taxpayer’s regular trade or business operations, or any amounts which could be included in apportionable income without violating the due process clause of the United States Constitution. For purposes of this definition, “income” means gross receipts less all expenses directly or indirectly attributable thereto. Functionally related dividends are presumed to be business income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
      "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#FL.llc.effective_period.corporate_income_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
      "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#FL.llc.filing_rule.corporate_income_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Fla. Stat. § 220.22(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) A return with respect to the tax imposed by this code shall be made by every taxpayer for each taxable year in which such taxpayer either is liable for tax under this code or is required to make a federal income tax return, regardless of whether such taxpayer is liable for tax under this code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
      "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#FL.llc.tax_regime.corporate_income_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Fla. Stat. § 220.11(2)",
          "quote": "(2)(a) The tax imposed by this section shall be an amount equal to 5 1 / 2 percent of the taxpayer’s net income for the taxable year, except as provided in paragraph (b). (b) The tax rate imposed in paragraph (a) shall be adjusted as provided in s. 220.1105.",
          "role": "rate_and_base",
          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Fla. Stat. § 220.11(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) A tax measured by net income is hereby imposed on every taxpayer for each taxable year for the privilege of conducting business, earning or receiving income in this state, or being a resident or citizen of this state. Such tax shall be in addition to all other occupation, excise, privilege, and property taxes imposed by this state or by any political subdivision thereof, including any municipality or other district, jurisdiction, or authority of this state.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
      "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#FL.llc.treatment.corporate_income_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Fla. Stat. § 220.13(1)(b)4",
          "quote": "4. There shall be subtracted from such taxable income any amount of nonbusiness income included therein.",
          "role": "nonbusiness_income_subtraction",
          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
        },
        {
          "pinpoint": "Fla. Stat. § 220.03(1)(r)",
          "quote": "(r) “Nonbusiness income” means rents and royalties from real or tangible personal property, capital gains, interest, dividends, and patent and copyright royalties, to the extent that they do not arise from transactions and activities in the regular course of the taxpayer’s trade or business. The term “nonbusiness income” does not include income from tangible and intangible property if the acquisition, management, and disposition of the property constitute integral parts of the taxpayer’s regular trade or business operations, or any amounts which could be included in apportionable income without violating the due process clause of the United States Constitution. For purposes of this definition, “income” means gross receipts less all expenses directly or indirectly attributable thereto. Functionally related dividends are presumed to be business income.",
          "role": "nonbusiness_income_test",
          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
        },
        {
          "pinpoint": "Fla. Stat. § 220.16(2)(c)",
          "quote": "(c) Capital gains and losses from sales of intangible personal property are allocable to this state if the taxpayer’s commercial domicile is in this state.",
          "role": "intangible_gain_allocation",
          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
        },
        {
          "pinpoint": "Fla. Stat. § 220.16(3)",
          "quote": "(3) Interest and dividends are allocable to this state if the taxpayer’s commercial domicile is in this state.",
          "role": "interest_and_dividend_allocation",
          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
        },
        {
          "pinpoint": "Fla. Stat. § 220.16(4)",
          "quote": "(4)(a) Patent and copyright royalties are allocable to this state: 1. If, and to the extent that, the patent or copyright is utilized by the payor in this state; or 2. If, and to the extent that, the patent or copyright is utilized by the payor in a state in which the taxpayer is not taxable and the taxpayer’s commercial domicile is in this state. (b) A patent is utilized in a state to the extent that it is employed in production, fabrication, manufacturing, or other processing in the state or to the extent that a patented product is produced in the state. If the basis of receipts from patent royalties does not permit allocation to states or if the accounting procedures do not reflect states of utilization, the patent is utilized in the state in which the taxpayer’s commercial domicile is located. (c) A copyright is utilized in a state to the extent that printing or other publication originates in the state. If the basis of receipts from copyright royalties does not permit allocation to states or if the accounting procedures do not reflect states of utilization, the copyright is utilized in the state in which the taxpayer’s commercial domicile is located.",
          "role": "royalty_allocation",
          "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
          "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
          "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All"
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      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Fla. Stat. § 220.12",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For purposes of this code, a taxpayer’s net income for a taxable year shall be its adjusted federal income, or that share of its adjusted federal income for such year which is apportioned to this state under s. 220.15, plus nonbusiness income allocated to this state pursuant to s. 220.16, less the exemption allowed by s. 220.14.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/FL/snapshots/c50/FL/fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c.html",
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      "source_class": "S1",
      "source_sha256": "fd8d8960bdfd53c0a14da080508d759bc0fd9914f8683eba325c9406fcb11e3c",
      "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#GA.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate-income-tax base is located at O.C.G.A. § 48-7-21 and Rule 560-7-3-.06(1).",
      "fetch_event_id": null,
      "pinpoint": "Ga. Comp. R. & Regs. 560-7-3-.06(1)",
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      "publish_status": "publish_ready",
      "quote": "Georgia taxable income of a corporation before apportionment and allocation shall be computed pursuant to O.C.G.A. § 48-7-21.",
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      "source_url": "https://rules.sos.ga.gov/gac/560-7-3",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#GA.llc.base_tax_locator.corporate_net_worth_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate net-worth-tax base and table are located in O.C.G.A. §§ 48-13-71 through 48-13-73 and the IT-611 net-worth schedules.",
      "fetch_event_id": null,
      "pinpoint": "2025 IT-611, Computation of Net Worth Tax",
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      "publish_status": "publish_ready",
      "quote": "The tax is graduated based on net worth (see page 8 for the table). In the case of new corporations, this is the beginning net worth. Thereafter, it is the net worth on the first day of the corporation’s net worth taxable year.",
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      "source_url": "https://dor.georgia.gov/document/document/2025-it611-corporate-income-tax-instruction-booklet/download",
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    "holding_tax:pp-holding-entity-tax#GA.llc.base_tax_locator.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective PTE tax base is located in O.C.G.A. §§ 48-7-21 and 48-7-23 and Rule 560-7-3-.03(6).",
      "fetch_event_id": null,
      "pinpoint": "Ga. Comp. R. & Regs. 560-7-3-.03(6)(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The electing pass-through entity shall multiply its income that is taxed at the entity level by 5.75 percent or, if subsequently changed, the applicable statutory income tax rate to arrive at the tax levied by Chapter 7 of Title 48.",
      "readiness": "ready",
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      "rendered": "value",
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      "source_url": "https://rules.sos.ga.gov/gac/560-7-3",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#GA.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The cited dividend rule defines an affiliated corporation by IRC § 1504 group membership; it does not state a general deduction for every investment holding.",
      "fetch_event_id": null,
      "pinpoint": "Ga. Comp. R. & Regs. 560-7-3-.06(2)",
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      "publish_status": "publish_ready",
      "quote": "For purposes of the affiliated corporations dividend deduction provided in O.C.G.A. § 48-7-21, the term \"affiliated corporation\" means a corporation that is a member of the taxpayer's \"affiliated group\" within the meaning of § 1504 of the Internal Revenue Code. This shall apply whether or not the affiliated group files a federal consolidated return.",
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      "source_sha256": "00487114f5463aeb980d5127c4b6c6f562089000b3f66dac29cc70ec9d9b24be",
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    "holding_tax:pp-holding-entity-tax#GA.llc.does_not_reach.corporate_net_worth_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "2025 IT-611, General Information: Net Worth",
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      "publish_status": "publish_ready",
      "quote": "A dormant corporation must file a net worth tax return and pay the tax, if applicable, to retain its charter. A foreign corporation admitted into Georgia must file a net worth tax return until it has withdrawn from Georgia. A corporation with a deficit net worth must file a return but does not owe the net worth tax. A corporation which has been liquidated and is filing its final income tax return is not required to file a net worth tax return, nor is it entitled to a refund of previously paid net worth tax.",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
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      "display": "The securities exemption does not cover the stated family-controlled entities, participating managers, or owners in a unitary business with a participating manager.",
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      "pinpoint": "2025 IT-711, Nonresident Withholding; limits on O.C.G.A. § 48-7-24(c)",
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      "publish_status": "publish_ready",
      "quote": "Note: This exemption does not apply to a family limited partnership or similar nontaxable entity, the majority interest of which is owned by one or more natural or naturalized citizens related to each other within the fourth degree of reckoning according to the laws of descent and distribution. Also, this exemption does not apply to a partner that participates in the management of the partnership or that is engaged in a unitary business with another person (including entities) that participates in the management of the partnership.",
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    "holding_tax:pp-holding-entity-tax#GA.llc.effective_period.corporate_income_tax": {
      "additional_sources": [
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          "pinpoint": "2025 IT-611, full text",
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      ],
      "capture_date": "2026-10-03",
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      "display": "No effective or sunset period for the current corporate-income-tax regime or affiliated-corporation dividend rule was stated in the searched official materials.",
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      ],
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      "display": "No effective or sunset period for the current corporate net-worth-tax regime was stated in the searched official materials.",
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      "capture_date": "2026-10-03",
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      "display": "The PTE-election regulation applies to taxable years beginning on or after January 1, 2022.",
      "fetch_event_id": null,
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      "display": "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.",
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      "quote": "The election is made by checking the box and filling out the applicable schedule(s) on Form 600S if the entity is a S Corporation or on Form 700 if the entity is a Partnership. The election must be made by the due date or extended due date of the entity’s income tax return and is irrevocable after the applicable due date passes.",
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      "display": "Georgia imposes a corporate income tax on corporations.",
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      "quote": "(8) There shall be subtracted from taxable income dividends received by: (A) A corporation from sources outside the United States as defined in the Internal Revenue Code of 1986. For purposes of this subparagraph, dividends received by a corporation from sources outside of the United States shall include amounts treated as a dividend and income deemed to have been received under provisions of the Internal Revenue Code of 1986 by such corporation if such amounts could have been subtracted from taxable income under this paragraph, had such amounts actually been received. The deduction provided by Section 250 shall apply to the extent the same income was included in Georgia taxable net income. The deduction, exclusion, or subtraction provided by Section 245A, Section 965, or any other section of the Internal Revenue Code of 1986 shall not apply to the extent income has been subtracted pursuant to this subparagraph. Amounts to be subtracted under this subparagraph shall include the following unless excluded by this paragraph, as defined by the Internal Revenue Code of 1986: (i) Qualified electing fund income; (ii) Subpart F income, including income specified in Section 951A of the Internal Revenue Code of 1986; and (iii) Income attributable to an increase in United States property by a controlled foreign corporation. The amount subtracted under this subparagraph shall be reduced by any expenses directly attributable to the dividend income; and (B) Corporations from affiliated corporations within the United States, when the corporation receiving the dividends is engaged in business in this state and is subject to the payment of taxes under the income tax laws of this state, to the extent that the dividends have been included in net income under this Code section. Dividends from affiliates shall be reduced by any expenses directly attributable to the dividend income.",
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      "quote": "rates herein provided shall be assessed, levied, collected, and paid for each taxable year on the taxable income of every corporation, including a corporation carrying on business in partnership, except that in the case of a regulated investment company the tax is as provided by subsection (b) and further that in the case of a real estate investment trust as defined in section 856 of the Internal Revenue Code of 1954 the tax is as provided in subsection (d). “Corporation” includes any professional corporation incorporated pursuant to chapter 415A.",
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      "quote": "(b) Notwithstanding any provision of law to the contrary, the following tax is imposed on each electing pass-through entity: the sum of all qualified member’s distributive shares and guaranteed payments of Hawaii taxable income as calculated under this chapter, multiplied by nine per cent. If the income calculated pursuant to this subsection reflects a net loss for the electing pass-through entity, the net loss may be carried forward to subsequent tax years for as long as the electing pass-through entity elects to be subject to the tax pursuant to this section until exhausted.",
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    "holding_tax:pp-holding-entity-tax#HI.llc.base_tax_locator.general_excise_tax": {
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      "display": "The other-business gross-income base and rate are located in §237-13(9), with gross income defined in §237-3; no amount is transcribed here.",
      "fetch_event_id": null,
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      "publish_status": "publish_ready",
      "quote": "(9) Tax on other business. Upon every person engaging or continuing within the State in any business, trade, activity, occupation, or calling not included in the preceding paragraphs or any other provisions of this chapter, there is likewise hereby levied and shall be assessed and collected, a tax equal to four per cent of the gross income thereof. In addition, the rate prescribed by this paragraph shall apply to a business taxable under one or more of the preceding paragraphs or other provisions of this chapter, as to any gross income thereof not taxed thereunder as gross income or gross proceeds of sales or by taxing an equivalent value of products, unless specifically exempted.",
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
      "table": "holding_tax"
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      "display": "The entity-level base and corporate-rate cross-reference are located in §235-122(b); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-122(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) Except as provided in the following sentence, an S corporation shall not be subject to the tax imposed by section 235-71. If income of an S corporation is subject to federal income tax, then such income as modified by section 235-123, to the extent it constitutes income attributable to the State, shall be taxed at the highest marginal rate of tax imposed on the net income of corporations. If an S corporation is required to pay a tax to this State by reason of the preceding sentence, then the income attributable to the State of the S corporation shall be reduced by the amount of the tax.",
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      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/HI/7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99.pdf",
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#HI.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The dividend rules remove the stated deductible portions from Hawaii taxable income; they do not state a general exemption for a holding LLC.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-7(c)(1)-(4)",
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      "publish_status": "publish_ready",
      "quote": "(c) The deductions of or based on dividends paid or received, allowed to a corporation under Chapter 1, Subchapter B, Part VIII of the Internal Revenue Code, shall not be allowed. In lieu thereof there shall be allowed as a deduction the entire amount of: (1) Dividends received by any corporation upon the shares of stock of a national banking association; (2) Qualifying dividends, as defined in Section 243(b) of the Internal Revenue Code, received by members of an affiliated group; provided that “includible corporation” as used therein shall include domestic and foreign corporations; (3) Dividends received by a small business investment company operating under the Small Business Investment Act of 1958 (Public Law 85-699); (4) Seventy per cent of the amount received by any corporation as dividends upon the shares of stock of another corporation, if otherwise allowed under section 243 of the Internal Revenue Code.",
      "readiness": "ready",
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#HI.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
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      "display": "The statutory definitions exclude publicly traded partnerships and limit qualified members to individuals, trusts, and estates.",
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      "pinpoint": "HRS §235-51.5(h), definitions of ‘Partnership’ and ‘Qualified member’",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "“Partnership” means the same as in the Internal Revenue Code. “Partnership” includes a limited liability company that is treated as a partnership for federal income tax purposes but does not include any publicly traded partnership within the meaning of section 7704 of the Internal Revenue Code. “Qualified member” means a member of an electing pass-through entity that is an individual, trust, or estate.",
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#HI.llc.does_not_reach.general_excise_tax": {
      "additional_sources": [
        {
          "pinpoint": "HRS §237-23.5(a)",
          "quote": "(a) This chapter shall not apply to amounts received, charged, or attributable to services furnished by one related entity to another related entity or to imputed or stated interest attributable to loans, advances, or use of capital between related entities.",
          "role": "related-entity interest exemption",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The gross-income definition excludes specified securities-sale and indebtedness receipts and dividends; §237-23.5 separately exempts qualifying related-entity interest.",
      "fetch_event_id": null,
      "pinpoint": "HRS §237-3(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) The words “gross income” and “gross proceeds of sales” shall not be construed to include: gross receipts from the sale of securities as defined in 15 United States Code section 78c or similar laws of jurisdictions outside the United States, contracts for the sale of a commodity for future delivery and other agreements, options, and rights as defined in 7 United States Code section 2 that are permitted to be traded on a board of trade designated by the Commodities Futures Trading Commission under the Commodity Exchange Act, or evidence of indebtedness or, except as otherwise provided, from the sale of land in fee simple, improved or unimproved, dividends as defined by chapter 235; cash discounts allowed and taken on sales;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/df9e86e5b441b33ab5cf3b917b04b1ddc2354a46eef7a416bbb7bfd25fad8327.pdf",
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
      "table": "holding_tax"
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Outside the stated federally taxed-income exception, an S corporation is not subject to the corporation tax imposed by §235-71.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-122(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) Except as provided in the following sentence, an S corporation shall not be subject to the tax imposed by section 235-71. If income of an S corporation is subject to federal income tax, then such income as modified by section 235-123, to the extent it constitutes income attributable to the State, shall be taxed at the highest marginal rate of tax imposed on the net income of corporations. If an S corporation is required to pay a tax to this State by reason of the preceding sentence, then the income attributable to the State of the S corporation shall be reduced by the amount of the tax.",
      "readiness": "ready",
      "reason_code": null,
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    "holding_tax:pp-holding-entity-tax#HI.llc.effective_period.corporate_income_tax": {
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      "claim_type": "negative_full_text_search",
      "display": "No current effective or sunset period for the corporate levy or dividend modification was stated in the complete chapter 235 capture.",
      "fetch_event_id": null,
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      "publish_status": "publish_ready",
      "quote": null,
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#HI.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
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      "display": "The elective pass-through entity tax applies to taxable years beginning after December 31, 2022.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-51.5, note following subsection (h)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Section applies to taxable years beginning after December 31, 2022.",
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#HI.llc.effective_period.general_excise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No current effective or sunset period for the general excise tax was stated in the complete chapter 237 capture.",
      "fetch_event_id": null,
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      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/df9e86e5b441b33ab5cf3b917b04b1ddc2354a46eef7a416bbb7bfd25fad8327.pdf",
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    "holding_tax:pp-holding-entity-tax#HI.llc.effective_period.s_corporation_entity_level_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No current effective or sunset period for the Part VII entity-level exception was stated in the complete chapter 235 capture.",
      "fetch_event_id": null,
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      "publish_status": "publish_ready",
      "quote": null,
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      "source_sha256": "7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#HI.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-92(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) Every corporation having for the taxable year gross income subject to taxation under this chapter; provided that an affiliated group of domestic corporations may make and file a consolidated return for the taxable year in lieu of separate tax returns in the manner and to the extent, so far as applicable, set forth in sections 1501 through 1505 and 1552 of the Internal Revenue Code of 1954, as amended.",
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      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/HI/7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#HI.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-51.5(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) A partnership or S corporation may elect to be taxed pursuant to this section as an electing pass-through entity in any tax year; provided that a separate election shall be made for each taxable year. An election made pursuant to this subsection shall be filed in the form and manner prescribed by the director of taxation and signed by: (1) Each member of the entity who is a member at the time the election is filed; or (2) Any officer, manager, or member of the entity who is authorized to make the election and who attests to having such authorization under penalty of perjury; provided that once the election is made, it shall be irrevocable for that taxable year and shall be binding on all partners, shareholders, and members of the electing pass-through entity.",
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      "reason_code": null,
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#HI.llc.filing_rule.general_excise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Each taxpayer files an annual return by the twentieth day of the fourth month after the taxable year closes.",
      "fetch_event_id": null,
      "pinpoint": "HRS §237-33",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "On or before the twentieth day of the fourth month following the close of the taxable year, each taxpayer shall make a return showing the value of products, gross proceeds of sales or gross income, and compute the amount of tax chargeable against the taxpayer in accordance with this chapter and deduct the amount of monthly payments (as hereinbefore provided), and transmit with the taxpayer’s report a remittance in the form required by section 237-31 covering the residue of the tax chargeable against the taxpayer.",
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
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    "holding_tax:pp-holding-entity-tax#HI.llc.filing_rule.s_corporation_entity_level_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "An S corporation files an annual Hawaii return when its Hawaii activities would require a C corporation return under §235-92.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-128(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) An S corporation which engages in activities in this State which would subject a C corporation to the requirement to file a return under section 235-92 shall file with the department an annual return, in the form prescribed by the department, on or before the due date prescribed for the filing of C corporation returns by section 235-97.",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Hawaii imposes tax on the taxable income of every corporation, including a corporation carrying on business in partnership.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-71(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "rates herein provided shall be assessed, levied, collected, and paid for each taxable year on the taxable income of every corporation, including a corporation carrying on business in partnership, except that in the case of a regulated investment company the tax is as provided by subsection (b) and further that in the case of a real estate investment trust as defined in section 856 of the Internal Revenue Code of 1954 the tax is as provided in subsection (d). “Corporation” includes any professional corporation incorporated pursuant to chapter 415A.",
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      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "An electing partnership or S corporation pays entity-level tax on qualified members' Hawaii taxable distributive shares and guaranteed payments.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-51.5(b)",
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      "publish_status": "publish_ready",
      "quote": "(b) Notwithstanding any provision of law to the contrary, the following tax is imposed on each electing pass-through entity: the sum of all qualified member’s distributive shares and guaranteed payments of Hawaii taxable income as calculated under this chapter, multiplied by nine per cent. If the income calculated pursuant to this subsection reflects a net loss for the electing pass-through entity, the net loss may be carried forward to subsequent tax years for as long as the electing pass-through entity elects to be subject to the tax pursuant to this section until exhausted.",
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      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Hawaii imposes general excise tax on gross income from a business or activity not otherwise taxed under chapter 237.",
      "fetch_event_id": null,
      "pinpoint": "HRS §237-13(9)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(9) Tax on other business. Upon every person engaging or continuing within the State in any business, trade, activity, occupation, or calling not included in the preceding paragraphs or any other provisions of this chapter, there is likewise hereby levied and shall be assessed and collected, a tax equal to four per cent of the gross income thereof. In addition, the rate prescribed by this paragraph shall apply to a business taxable under one or more of the preceding paragraphs or other provisions of this chapter, as to any gross income thereof not taxed thereunder as gross income or gross proceeds of sales or by taxing an equivalent value of products, unless specifically exempted.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/df9e86e5b441b33ab5cf3b917b04b1ddc2354a46eef7a416bbb7bfd25fad8327.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "df9e86e5b441b33ab5cf3b917b04b1ddc2354a46eef7a416bbb7bfd25fad8327",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#HI.llc.tax_regime.s_corporation_entity_level_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-122(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) Except as provided in the following sentence, an S corporation shall not be subject to the tax imposed by section 235-71. If income of an S corporation is subject to federal income tax, then such income as modified by section 235-123, to the extent it constitutes income attributable to the State, shall be taxed at the highest marginal rate of tax imposed on the net income of corporations. If an S corporation is required to pay a tax to this State by reason of the preceding sentence, then the income attributable to the State of the S corporation shall be reduced by the amount of the tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/HI/7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#HI.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Corporate dividend income receives Hawaii-specific deduction treatment: full deductions for three stated classes and a 70% deduction for qualifying other-corporation dividends.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-7(c)(1)-(4)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) The deductions of or based on dividends paid or received, allowed to a corporation under Chapter 1, Subchapter B, Part VIII of the Internal Revenue Code, shall not be allowed. In lieu thereof there shall be allowed as a deduction the entire amount of: (1) Dividends received by any corporation upon the shares of stock of a national banking association; (2) Qualifying dividends, as defined in Section 243(b) of the Internal Revenue Code, received by members of an affiliated group; provided that “includible corporation” as used therein shall include domestic and foreign corporations; (3) Dividends received by a small business investment company operating under the Small Business Investment Act of 1958 (Public Law 85-699); (4) Seventy per cent of the amount received by any corporation as dividends upon the shares of stock of another corporation, if otherwise allowed under section 243 of the Internal Revenue Code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/HI/7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#HI.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The elective base uses all qualified members' Hawaii taxable distributive shares and guaranteed payments; no holding or passive carve-out was located.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-51.5(b); chapter 235 full text searched",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) Notwithstanding any provision of law to the contrary, the following tax is imposed on each electing pass-through entity: the sum of all qualified member’s distributive shares and guaranteed payments of Hawaii taxable income as calculated under this chapter, multiplied by nine per cent. If the income calculated pursuant to this subsection reflects a net loss for the electing pass-through entity, the net loss may be carried forward to subsequent tax years for as long as the electing pass-through entity elects to be subject to the tax pursuant to this section until exhausted.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/HI/7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#HI.llc.treatment.general_excise_tax": {
      "additional_sources": [
        {
          "pinpoint": "HRS §237-3(b)",
          "quote": "(b) The words “gross income” and “gross proceeds of sales” shall not be construed to include: gross receipts from the sale of securities as defined in 15 United States Code section 78c or similar laws of jurisdictions outside the United States, contracts for the sale of a commodity for future delivery and other agreements, options, and rights as defined in 7 United States Code section 2 that are permitted to be traded on a board of trade designated by the Commodities Futures Trading Commission under the Commodity Exchange Act, or evidence of indebtedness or, except as otherwise provided, from the sale of land in fee simple, improved or unimproved, dividends as defined by chapter 235; cash discounts allowed and taken on sales;",
          "role": "excluded receipts",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/df9e86e5b441b33ab5cf3b917b04b1ddc2354a46eef7a416bbb7bfd25fad8327.pdf",
          "source_sha256": "df9e86e5b441b33ab5cf3b917b04b1ddc2354a46eef7a416bbb7bfd25fad8327",
          "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Gross income includes receipts from invested business capital, including interest and royalties; specified securities-sale receipts and dividends are excluded.",
      "fetch_event_id": null,
      "pinpoint": "HRS §237-3(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) “Gross income” means the gross receipts, cash or accrued, of the taxpayer received as compensation for personal services and the gross receipts of the taxpayer derived from trade, business, commerce, or sales and the value proceeding or accruing from the sale of tangible personal property, or service, or both, and all receipts, actual or accrued as hereinafter provided, by reason of the investment of the capital of the business engaged in, including interest, discount, rentals, royalties, fees, or other emoluments however designated and without any deductions on account of the cost of property sold, the cost of materials used, labor cost, taxes, royalties, interest, or discount paid or any other expenses whatsoever.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/df9e86e5b441b33ab5cf3b917b04b1ddc2354a46eef7a416bbb7bfd25fad8327.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "df9e86e5b441b33ab5cf3b917b04b1ddc2354a46eef7a416bbb7bfd25fad8327",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#HI.llc.treatment.s_corporation_entity_level_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Federally taxed S-corporation income attributable to Hawaii is taxed at the highest marginal corporate rate and then reduces state-attributable S-corporation income.",
      "fetch_event_id": null,
      "pinpoint": "HRS §235-122(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) Except as provided in the following sentence, an S corporation shall not be subject to the tax imposed by section 235-71. If income of an S corporation is subject to federal income tax, then such income as modified by section 235-123, to the extent it constitutes income attributable to the State, shall be taxed at the highest marginal rate of tax imposed on the net income of corporations. If an S corporation is required to pay a tax to this State by reason of the preceding sentence, then the income attributable to the State of the S corporation shall be reduced by the amount of the tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/HI/snapshots/c50/HI/7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7426770f3028a5e920e6332ec06760bec6ee1a2a1ae3fff099909d2f9dc25f99",
      "source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IA.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The corporate income-tax base and rate mechanism are located at Iowa Code § 422.33(1); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.33(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax is imposed annually upon each corporation doing business in this state, or deriving income from sources within this state, in an amount computed by applying the following rates of taxation to the net income received by the corporation during the income year:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-code-ch422-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "be6d93d9c62cfafdd2504b89c255fdf82a62a470d1c53882e9fe5017638129be",
      "source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The PTET base and rate reference are located at Iowa Code § 422.16C(4)(a); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.16C(4)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A taxpayer making an election under this section shall be subject to tax in an amount equal to the rate under section 422.5, imposed against the taxable income of the taxpayer for the taxable year properly determined under this chapter and allocated and apportioned to the state under the rules adopted by the department. The tax shall be due with the taxpayer’s return required under this chapter.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-code-ch422-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "be6d93d9c62cfafdd2504b89c255fdf82a62a470d1c53882e9fe5017638129be",
      "source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.34A, introductory paragraph and subsection 5",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A foreign corporation shall not be considered doing business in this state or deriving income from sources within this state for the purposes of this subchapter by reason of carrying on in this state one or more of the following activities: […] Owning and controlling a subsidiary corporation which is incorporated in or which is transacting business within this state where the holding or parent company has no physical presence in the state as that presence relates to the ownership or control of the subsidiary.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-code-ch422-tax.html",
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      "source_class": "S1",
      "source_sha256": "be6d93d9c62cfafdd2504b89c255fdf82a62a470d1c53882e9fe5017638129be",
      "source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "A publicly traded partnership and a single-member or other federally disregarded LLC cannot make their own PTET election.",
      "fetch_event_id": null,
      "pinpoint": "Making a PTET Election, eligible entities",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A publicly traded partnership as defined in Internal Revenue Code section 7704 is not eligible to make the PTET election. A single-member LLC or other entity treated as a disregarded entity for federal and Iowa tax purposes is not eligible to make its own PTET election.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-revenue-ptet.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4ae788980c7da9f90765b624565ea4788c91b7be7a55ccf75a53314860e9fb6a",
      "source_url": "https://revenue.iowa.gov/taxes/tax-guidance/business-income-tax/pass-through-entity-tax-ptet",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IA.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "The Department identifies the current corporate-rate schedule as effective for tax years beginning on or after January 1, 2024.",
      "fetch_event_id": null,
      "pinpoint": "Corporate Income Tax Rates - On or after January 1, 2024",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective for tax years beginning on or after January 1, 2024, the corporate income tax rates are as follows:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-revenue-corporate-income-tax-rates.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "04230df79d8e59bb76233f7a87b18252fb1ab26b79b098577032c63e7e5b6233",
      "source_url": "https://revenue.iowa.gov/taxes/tax-guidance/business-income-tax/iowa-corporate-income-tax-rates",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "The election is available for qualifying tax years beginning on or after January 1, 2022 and is no longer scheduled to expire.",
      "fetch_event_id": null,
      "pinpoint": "Making a PTET Election, tax years; updated 2025-12-22",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A PTET election only applies for one tax year. A separate election must be made for each tax year. Due to federal legislation, P.L. 119-21, the PTET election is no longer scheduled to expire. The PTET election may be made for any tax year beginning on or after January 1, 2022 that the individual limitation on the state and local tax (SALT) deduction under Internal Revenue Code section 164(b)(6) applies.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-revenue-ptet.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4ae788980c7da9f90765b624565ea4788c91b7be7a55ccf75a53314860e9fb6a",
      "source_url": "https://revenue.iowa.gov/taxes/tax-guidance/business-income-tax/pass-through-entity-tax-ptet",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.36(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A corporation shall make a return and the return shall be signed by the president or other duly authorized officer in accordance with forms and rules prescribed by the director.",
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      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-code-ch422-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "be6d93d9c62cfafdd2504b89c255fdf82a62a470d1c53882e9fe5017638129be",
      "source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A separate irrevocable election is made for each tax year, and the entity-level tax is due with the taxpayer's return.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.16C(3)(a), (4)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A separate election shall be made for each tax year on a form and at a time prescribed by the department. An election shall be irrevocable once made and shall be binding on the taxpayer and all partners or shareholders of the taxpayer. […] A taxpayer making an election under this section shall be subject to tax in an amount equal to the rate under section 422.5, imposed against the taxable income of the taxpayer for the taxable year properly determined under this chapter and allocated and apportioned to the state under the rules adopted by the department. The tax shall be due with the taxpayer’s return required under this chapter.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-code-ch422-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "be6d93d9c62cfafdd2504b89c255fdf82a62a470d1c53882e9fe5017638129be",
      "source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Iowa imposes corporate income tax on each corporation doing business in Iowa or deriving income from Iowa sources.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.33(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax is imposed annually upon each corporation doing business in this state, or deriving income from sources within this state, in an amount computed by applying the following rates of taxation to the net income received by the corporation during the income year:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-code-ch422-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "be6d93d9c62cfafdd2504b89c255fdf82a62a470d1c53882e9fe5017638129be",
      "source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "An electing taxpayer pays entity-level tax on its properly determined Iowa taxable income, allocated and apportioned under Department rules.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.16C(4)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A taxpayer making an election under this section shall be subject to tax in an amount equal to the rate under section 422.5, imposed against the taxable income of the taxpayer for the taxable year properly determined under this chapter and allocated and apportioned to the state under the rules adopted by the department. The tax shall be due with the taxpayer’s return required under this chapter.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-code-ch422-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "be6d93d9c62cfafdd2504b89c255fdf82a62a470d1c53882e9fe5017638129be",
      "source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IA.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.34A, introductory paragraph and subsection 5",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A foreign corporation shall not be considered doing business in this state or deriving income from sources within this state for the purposes of this subchapter by reason of carrying on in this state one or more of the following activities: […] Owning and controlling a subsidiary corporation which is incorporated in or which is transacting business within this state where the holding or parent company has no physical presence in the state as that presence relates to the ownership or control of the subsidiary.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IA/snapshots/ia-code-ch422-tax.html",
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      "source_class": "S1",
      "source_sha256": "be6d93d9c62cfafdd2504b89c255fdf82a62a470d1c53882e9fe5017638129be",
      "source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IA.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": null,
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      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Iowa Code § 422.16C(4)(a)",
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      "quote": "A taxpayer making an election under this section shall be subject to tax in an amount equal to the rate under section 422.5, imposed against the taxable income of the taxpayer for the taxable year properly determined under this chapter and allocated and apportioned to the state under the rules adopted by the department. The tax shall be due with the taxpayer’s return required under this chapter.",
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    "holding_tax:pp-holding-entity-tax#ID.llc.base_tax_locator.affected_business_entity_tax": {
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      "fetch_event_id": null,
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      "quote": "For taxable years commencing on and after January 1, 2001, a franchise tax shall be imposed upon any corporation, other than an S corporation, for the privilege of exercising its corporate franchise within the state during such taxable year including, but not limited to, corporations engaged in business in Idaho for the exclusive purpose of performing contracts with the United States department of energy at the Idaho national laboratory or any successor organization, which tax shall be measured by income which is attributable to this state under the provisions of this chapter and which tax shall be at the rate provided in section 63-3025, Idaho Code.",
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    "holding_tax:pp-holding-entity-tax#ID.llc.base_tax_locator.corporate_income_tax": {
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      "fetch_event_id": null,
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      "quote": "For each taxable year, a tax is hereby imposed on the Idaho taxable income of a corporation, other than an S corporation, that transacts or is authorized to transact business in this state or has income attributable to this state.",
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      "additional_sources": [
        {
          "pinpoint": "Idaho Code § 63-3082(2)",
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          "source_sha256": "9168e8e8915931c7c9e5f4b80d19eb27303bf81fa94a328335dedcbca4da05ac",
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      "capture_date": "2026-10-02",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/9168e8e8915931c7c9e5f4b80d19eb27303bf81fa94a328335dedcbca4da05ac.html",
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        {
          "pinpoint": "Idaho Code § 63-3026B(1)(b)",
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      ],
      "capture_date": "2026-10-02",
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      "display": "The stated interest/dividend allocation reaches Idaho-commercial-domicile income unless apportionable; §63-3026B separately excludes an exempt member's apportioned share.",
      "fetch_event_id": null,
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      "publish_status": "publish_ready",
      "quote": "Interest and dividends are allocable to this state if the taxpayer’s commercial domicile is in this state, unless such interest or dividends constitute apportionable income as defined in this section.",
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      "quote": "\"Person\" as used in sections 63-3082 through 63-3087 , Idaho Code, means any individual, or entity required to file a return under section 63-3030 , Idaho Code, unless all of the income or loss is distributed or otherwise reportable as a part of the taxable income of another taxpayer and the entity does not have any Idaho taxable income.",
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      "display": "A partnership or S corporation may make a separate ABE election for any taxable year.",
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      "quote": "A partnership or an S corporation may elect in the manner set forth in this section to become an affected business entity required to pay the tax under this section in any taxable year. A separate election must be made for each taxable year.",
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      "public_reason": null,
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      "quote": "For taxable years commencing on and after January 1, 2001, a franchise tax shall be imposed upon any corporation, other than an S corporation, for the privilege of exercising its corporate franchise within the state during such taxable year including, but not limited to, corporations engaged in business in Idaho for the exclusive purpose of performing contracts with the United States department of energy at the Idaho national laboratory or any successor organization, which tax shall be measured by income which is attributable to this state under the provisions of this chapter and which tax shall be at the rate provided in section 63-3025, Idaho Code.",
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      "quote": "For each taxable year, commencing on and after January 1, 2025, the tax imposed by this section is changed and shall be equal to five and three-tenths percent (5.3%) of Idaho taxable income.",
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        {
          "pinpoint": "Idaho Code § 63-3026B(2)(a)",
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      "quote": "Each affected business entity that is a partnership or an S corporation transacting business in this state shall, on or before the fifteenth day of the fourth month following the close of each taxable year, pay a tax in an amount determined as follows:",
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      "display": "The corporate Idaho return is due on the fifteenth day of the fourth month after the tax year closes.",
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      "pinpoint": "Idaho Tax Commission, Income Tax for Corporations, ‘When to file’",
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    "holding_tax:pp-holding-entity-tax#ID.llc.filing_rule.permanent_building_fund_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The additional tax is tied to the obligation to file an income-tax return and is paid by the return filer.",
      "fetch_event_id": null,
      "pinpoint": "Idaho Code § 63-3082(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every person required to file an income tax return shall pay a tax of ten dollars ($10.00). For this purpose, a husband and wife filing a joint return shall be deemed a single person. This tax shall be in the nature of an excise tax upon the receipt of the income which requires the filing of such return.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/9168e8e8915931c7c9e5f4b80d19eb27303bf81fa94a328335dedcbca4da05ac.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9168e8e8915931c7c9e5f4b80d19eb27303bf81fa94a328335dedcbca4da05ac",
      "source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3082/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#ID.llc.tax_regime.affected_business_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "An electing partnership or S corporation transacting business in Idaho pays entity-level tax on its Idaho-source affected-business-entity income.",
      "fetch_event_id": null,
      "pinpoint": "Idaho Code § 63-3026B(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each affected business entity that is a partnership or an S corporation transacting business in this state shall, on or before the fifteenth day of the fourth month following the close of each taxable year, pay a tax in an amount determined as follows:",
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      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/ca33be09a8c2c65c7d1462fec5726b34bc3fa6f112d5ac908eaf123fe216da1d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3026B/",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#ID.llc.tax_regime.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Income Tax for Corporations, federal regulations",
          "quote": "If an entity is classified or taxed as a corporation for federal income tax purposes, it’s treated as a corporation for Idaho income tax purposes.",
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          "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/id-tax-corporation-income-franchise.html",
          "source_sha256": "8292a7d58c073409fbfe764747ed306383defd8295109c55a88aa2266380a94d",
          "source_url": "https://tax.idaho.gov/taxes/income-tax/business-income/guides-for-certain-businesses/income-tax-for-corporations/"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "Idaho imposes the franchise tax on the corporate branch described in Idaho Code § 63-3025A.",
      "fetch_event_id": null,
      "pinpoint": "Idaho Code § 63-3025A",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years commencing on and after January 1, 2001, a franchise tax shall be imposed upon any corporation, other than an S corporation, for the privilege of exercising its corporate franchise within the state during such taxable year including, but not limited to, corporations engaged in business in Idaho for the exclusive purpose of performing contracts with the United States department of energy at the Idaho national laboratory or any successor organization, which tax shall be measured by income which is attributable to this state under the provisions of this chapter and which tax shall be at the rate provided in section 63-3025, Idaho Code.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/774daa9e807a5f96bc8e9d8c243f3eab1a6a8f9765398e60ab948326fdece634.html",
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      "source_class": "S1",
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      "source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025A/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#ID.llc.tax_regime.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Income Tax for Corporations, federal regulations",
          "quote": "If an entity is classified or taxed as a corporation for federal income tax purposes, it’s treated as a corporation for Idaho income tax purposes.",
          "role": "LLC federal-classification coverage",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/id-tax-corporation-income-franchise.html",
          "source_sha256": "8292a7d58c073409fbfe764747ed306383defd8295109c55a88aa2266380a94d",
          "source_url": "https://tax.idaho.gov/taxes/income-tax/business-income/guides-for-certain-businesses/income-tax-for-corporations/"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "Idaho imposes the tax on corporate income on the corporate branch described in Idaho Code § 63-3025.",
      "fetch_event_id": null,
      "pinpoint": "Idaho Code § 63-3025",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For each taxable year, a tax is hereby imposed on the Idaho taxable income of a corporation, other than an S corporation, that transacts or is authorized to transact business in this state or has income attributable to this state.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/65f6862ea3ab51359ef4df3a3104544ce8c47e53cc20a8fafb9b2395a182600a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025/",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#ID.llc.tax_regime.permanent_building_fund_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "Every person required to file an Idaho income-tax return pays the additional excise tax imposed by §63-3082.",
      "fetch_event_id": null,
      "pinpoint": "Idaho Code § 63-3082(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every person required to file an income tax return shall pay a tax of ten dollars ($10.00). For this purpose, a husband and wife filing a joint return shall be deemed a single person. This tax shall be in the nature of an excise tax upon the receipt of the income which requires the filing of such return.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/9168e8e8915931c7c9e5f4b80d19eb27303bf81fa94a328335dedcbca4da05ac.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3082/",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#ID.llc.treatment.affected_business_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "complete primary statute searched in full",
      "display": "The complete ABE-tax section states no holding or passive-entity exemption or different treatment.",
      "fetch_event_id": null,
      "pinpoint": "Idaho Code § 63-3026B, complete section",
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      "publish_status": "publish_ready",
      "quote": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/ca33be09a8c2c65c7d1462fec5726b34bc3fa6f112d5ac908eaf123fe216da1d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ca33be09a8c2c65c7d1462fec5726b34bc3fa6f112d5ac908eaf123fe216da1d",
      "source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3026B/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#ID.llc.treatment.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Idaho Code § 63-3025A",
          "quote": "For taxable years commencing on and after January 1, 2001, a franchise tax shall be imposed upon any corporation, other than an S corporation, for the privilege of exercising its corporate franchise within the state during such taxable year including, but not limited to, corporations engaged in business in Idaho for the exclusive purpose of performing contracts with the United States department of energy at the Idaho national laboratory or any successor organization, which tax shall be measured by income which is attributable to this state under the provisions of this chapter and which tax shall be at the rate provided in section 63-3025, Idaho Code.",
          "role": "primary imposition statute",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/774daa9e807a5f96bc8e9d8c243f3eab1a6a8f9765398e60ab948326fdece634.html",
          "source_sha256": "774daa9e807a5f96bc8e9d8c243f3eab1a6a8f9765398e60ab948326fdece634",
          "source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025A/"
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      "capture_date": "2026-10-03",
      "claim_type": "official Tax Commission universal filing guidance",
      "display": "Tax Commission guidance lists an inactive or name-holder corporation among corporations that must file; it states no holding-only carve-out.",
      "fetch_event_id": null,
      "pinpoint": "Idaho Tax Commission, Income Tax for Corporations, examples of corporations that must file",
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      "publish_status": "publish_ready",
      "quote": "The following are examples of corporations that must file a business income tax return: […] An inactive or name-holder corporation",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/id-tax-corporation-income-franchise.html",
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      "source_sha256": "8292a7d58c073409fbfe764747ed306383defd8295109c55a88aa2266380a94d",
      "source_url": "https://tax.idaho.gov/taxes/income-tax/business-income/guides-for-certain-businesses/income-tax-for-corporations/",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#ID.llc.treatment.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Idaho Code § 63-3025",
          "quote": "For each taxable year, a tax is hereby imposed on the Idaho taxable income of a corporation, other than an S corporation, that transacts or is authorized to transact business in this state or has income attributable to this state.",
          "role": "primary imposition statute",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/c50/ID/65f6862ea3ab51359ef4df3a3104544ce8c47e53cc20a8fafb9b2395a182600a.html",
          "source_sha256": "65f6862ea3ab51359ef4df3a3104544ce8c47e53cc20a8fafb9b2395a182600a",
          "source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025/"
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      "capture_date": "2026-10-03",
      "claim_type": "official Tax Commission universal filing guidance",
      "display": "Tax Commission guidance lists an inactive or name-holder corporation among corporations that must file; it states no holding-only carve-out.",
      "fetch_event_id": null,
      "pinpoint": "Idaho Tax Commission, Income Tax for Corporations, examples of corporations that must file",
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      "publish_status": "publish_ready",
      "quote": "The following are examples of corporations that must file a business income tax return: […] An inactive or name-holder corporation",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ID/snapshots/id-tax-corporation-income-franchise.html",
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    "holding_tax:pp-holding-entity-tax#ID.llc.treatment.permanent_building_fund_tax": {
      "additional_sources": [
        {
          "pinpoint": "Idaho Code § 63-3082(1), the $10 tax on every person required to file",
          "quote": "(1) Every person required to file an income tax return shall pay a tax of ten dollars ($10.00).",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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)).",
      "fetch_event_id": null,
      "pinpoint": "Idaho Code § 63-3083; Idaho Code § 63-3082(1)",
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      "publish_status": "publish_ready",
      "quote": "\"Person\" as used in sections 63-3082 through 63-3087 , Idaho Code, means any individual, or entity required to file a return under section 63-3030 , Idaho Code, unless all of the income or loss is distributed or otherwise reportable as a part of the taxable income of another taxpayer and the entity does not have any Idaho taxable income.",
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      "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/c.13.holding-tax-2/ID/89f7e65d2d5d8bf561f35b22dc324c9a7ecec2e24b8c8a13a1c85f05e81bc332.html",
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      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#IL.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(a)",
          "quote": "(a) In general. A tax measured by net income is hereby imposed on every individual, corporation, trust and estate for each taxable year ending after July 31, 1969 on the privilege of earning or receiving income in or as a resident of this State. Such tax shall be in addition to all other occupation or privilege taxes imposed by this State or by any municipal corporation or political subdivision thereof.",
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          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
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      "display": "The corporate net-income imposition is located at 35 ILCS 5/201(a), and the current corporate rate at 35 ILCS 5/201(b)(14).",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(b)(14)",
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      "publish_status": "publish_ready",
      "quote": "(14) In the case of a corporation, for taxable years beginning on or after July 1, 2017, an amount equal to 7% of the taxpayer's net income for the taxable year.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
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      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
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    "holding_tax:pp-holding-entity-tax#IL.llc.base_tax_locator.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(p)(3)(B)",
          "quote": "(B) Special rule for tiered partnerships. If a taxpayer making the election under paragraph (1) is a partner of another taxpayer making the election under paragraph (1), net income shall be computed as provided in subparagraph (A), except that the taxpayer shall subtract its distributive share of the net income of the electing partnership (including its distributive share of the net income of the electing partnership derived as a distributive share from electing partnerships in which it is a partner).",
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      "capture_date": "2026-10-03",
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      "display": "The entity-level PTE tax and rate are located at 35 ILCS 5/201(p)(2), and the net-income rules at paragraph (3).",
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      "pinpoint": "35 ILCS 5/201(p)(2)",
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      "publish_status": "publish_ready",
      "quote": "(2) Entity-level tax. A partnership or Subchapter S corporation electing to apply the provisions of this subsection shall be subject to a tax for the privilege of earning or receiving income in this State in an amount equal to 4.95% of the taxpayer's net income for the taxable year.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
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      "source_class": "S1",
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      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
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    "holding_tax:pp-holding-entity-tax#IL.llc.base_tax_locator.personal_property_tax_replacement_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(c)",
          "quote": "(c) Personal Property Tax Replacement Income Tax. Beginning on July 1, 1979 and thereafter, in addition to such income tax, there is also hereby imposed the Personal Property Tax Replacement Income Tax measured by net income on every corporation (including Subchapter S corporations), partnership and trust, for each taxable year ending after June 30, 1979. Such taxes are imposed on the privilege of earning or receiving income in or as a resident of this State. The Personal Property Tax Replacement Income Tax shall be in addition to the income tax imposed by subsections (a) and (b) of this Section and in addition to all other occupation or privilege taxes imposed by this State or by any municipal corporation or political subdivision thereof.",
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          "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
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      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The replacement-tax imposition is located at 35 ILCS 5/201(c), and the corporation, partnership, trust, and S-corporation rates at subsection (d).",
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      "pinpoint": "35 ILCS 5/201(d)",
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      "quote": "(d) Additional Personal Property Tax Replacement Income Tax Rates. The personal property tax replacement income tax imposed by this subsection and subsection (c) of this Section in the case of a corporation, other than a Subchapter S corporation and except as adjusted by subsection (d-1), shall be an additional amount equal to 2.85% of such taxpayer's net income for the taxable year, except that beginning on January 1, 1981, and thereafter, the rate of 2.85% specified in this subsection shall be reduced to 2.5%, and in the case of a partnership, trust or a Subchapter S corporation shall be an additional amount equal to 1.5% of such taxpayer's net income for the taxable year.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
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      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/1501(a)(27)(C)(ii)",
          "quote": "(ii) The income of a holding company which is a member of more than one unitary business group shall be included in each unitary business group of which it is a member on a pro rata basis, by including in each unitary business group that portion of the base income of the holding company that bears the same proportion to the total base income of the holding company as the gross receipts of the unitary business group bears to the combined gross receipts of all unitary business groups (in both cases without regard to the holding company) or on any other reasonable basis, consistently applied.",
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          "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/1501(a)(27)(C)(i)-(iii), stated limits",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(C) Holding companies. (i) For purposes of this subparagraph, a \"holding company\" is a corporation (other than a corporation that is a financial organization under paragraph (8) of this subsection (a) of Section 1501 because it is a bank holding company under the provisions of the Bank Holding Company Act of 1956 (12 U.S.C. 1841, et seq.) or because it is owned by a bank or a bank holding company) that owns a controlling interest in one or more other taxpayers (\"controlled taxpayers\"); that, during the period that includes the taxable year and the 2 immediately preceding taxable years or, if the corporation was formed during the current or immediately preceding taxable year, the taxable years in which the corporation has been in existence, derived substantially all its gross income from dividends, interest, rents, royalties, fees or other charges received from controlled taxpayers for the provision of services, and gains on the sale or other disposition of interests in controlled taxpayers or in property leased or licensed to controlled taxpayers or used by the taxpayer in providing services to controlled taxpayers; and that incurs no substantial expenses other than expenses (including interest and other costs of borrowing) incurred in connection with the acquisition and holding of interests in controlled taxpayers and in the provision of services to controlled taxpayers or in the leasing or licensing of property to controlled taxpayers.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.does_not_reach.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(p)(3)(B)",
          "quote": "(B) Special rule for tiered partnerships. If a taxpayer making the election under paragraph (1) is a partner of another taxpayer making the election under paragraph (1), net income shall be computed as provided in subparagraph (A), except that the taxpayer shall subtract its distributive share of the net income of the electing partnership (including its distributive share of the net income of the electing partnership derived as a distributive share from electing partnerships in which it is a partner).",
          "role": "tiered_partnership_limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
          "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The election excludes publicly traded partnerships and years beginning in 2026 or later; the tiered subtraction requires an interest in another electing partnership.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(p)(1), stated exclusions",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) For taxable years ending on or after December 31, 2021 and beginning prior to January 1, 2026, a partnership (other than a publicly traded partnership under Section 7704 of the Internal Revenue Code) or Subchapter S corporation may elect to apply the provisions of this subsection. A separate election shall be made for each taxable year. Such election shall be made at such time, and in such form and manner as prescribed by the Department, and, once made, is irrevocable.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.does_not_reach.personal_property_tax_replacement_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/1501(a)(27)(C)(ii)",
          "quote": "(ii) The income of a holding company which is a member of more than one unitary business group shall be included in each unitary business group of which it is a member on a pro rata basis, by including in each unitary business group that portion of the base income of the holding company that bears the same proportion to the total base income of the holding company as the gross receipts of the unitary business group bears to the combined gross receipts of all unitary business groups (in both cases without regard to the holding company) or on any other reasonable basis, consistently applied.",
          "role": "multiple_unitary_group_limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
          "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/1501(a)(27)(C)(i)-(iii), stated limits",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(C) Holding companies. (i) For purposes of this subparagraph, a \"holding company\" is a corporation (other than a corporation that is a financial organization under paragraph (8) of this subsection (a) of Section 1501 because it is a bank holding company under the provisions of the Bank Holding Company Act of 1956 (12 U.S.C. 1841, et seq.) or because it is owned by a bank or a bank holding company) that owns a controlling interest in one or more other taxpayers (\"controlled taxpayers\"); that, during the period that includes the taxable year and the 2 immediately preceding taxable years or, if the corporation was formed during the current or immediately preceding taxable year, the taxable years in which the corporation has been in existence, derived substantially all its gross income from dividends, interest, rents, royalties, fees or other charges received from controlled taxpayers for the provision of services, and gains on the sale or other disposition of interests in controlled taxpayers or in property leased or licensed to controlled taxpayers or used by the taxpayer in providing services to controlled taxpayers; and that incurs no substantial expenses other than expenses (including interest and other costs of borrowing) incurred in connection with the acquisition and holding of interests in controlled taxpayers and in the provision of services to controlled taxpayers or in the leasing or licensing of property to controlled taxpayers.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The stated current corporate rate applies to taxable years beginning on or after July 1, 2017.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(b)(14)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(14) In the case of a corporation, for taxable years beginning on or after July 1, 2017, an amount equal to 7% of the taxpayer's net income for the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.effective_period.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(p)(10)",
          "quote": "(10) The provisions of this subsection shall apply only with respect to taxable years for which the limitation on individual deductions applies under Section 164(b)(6) of the Internal Revenue Code.",
          "role": "additional_period_condition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
          "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(p)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) For taxable years ending on or after December 31, 2021 and beginning prior to January 1, 2026, a partnership (other than a publicly traded partnership under Section 7704 of the Internal Revenue Code) or Subchapter S corporation may elect to apply the provisions of this subsection. A separate election shall be made for each taxable year. Such election shall be made at such time, and in such form and manner as prescribed by the Department, and, once made, is irrevocable.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.effective_period.personal_property_tax_replacement_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(d)",
          "quote": "(d) Additional Personal Property Tax Replacement Income Tax Rates. The personal property tax replacement income tax imposed by this subsection and subsection (c) of this Section in the case of a corporation, other than a Subchapter S corporation and except as adjusted by subsection (d-1), shall be an additional amount equal to 2.85% of such taxpayer's net income for the taxable year, except that beginning on January 1, 1981, and thereafter, the rate of 2.85% specified in this subsection shall be reduced to 2.5%, and in the case of a partnership, trust or a Subchapter S corporation shall be an additional amount equal to 1.5% of such taxpayer's net income for the taxable year.",
          "role": "rate_period",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
          "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The replacement tax begins July 1, 1979 for taxable years ending after June 30, 1979; subsection (d) states the later rate periods.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Personal Property Tax Replacement Income Tax. Beginning on July 1, 1979 and thereafter, in addition to such income tax, there is also hereby imposed the Personal Property Tax Replacement Income Tax measured by net income on every corporation (including Subchapter S corporations), partnership and trust, for each taxable year ending after June 30, 1979. Such taxes are imposed on the privilege of earning or receiving income in or as a resident of this State. The Personal Property Tax Replacement Income Tax shall be in addition to the income tax imposed by subsections (a) and (b) of this Section and in addition to all other occupation or privilege taxes imposed by this State or by any municipal corporation or political subdivision thereof.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.filing_rule.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/502(e), current-period sentence",
          "quote": "For taxable years ending on or after December 31, 1993, taxpayers that are corporations (other than Subchapter S corporations) and that are members of the same unitary business group shall be treated as one taxpayer for purposes of any original return, amended return which includes the same taxpayers of the unitary group which joined in filing the original return, extension, claim for refund, assessment, collection and payment and determination of the group's tax liability under this Act.",
          "role": "unitary_group_return_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/IL/bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c.html",
          "source_sha256": "bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K502.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/502(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) In general. A return with respect to the taxes imposed by this Act shall be made by every person for any taxable year: (1) for which such person is liable for a tax imposed by this Act, or (2) in the case of a resident or in the case of a corporation which is qualified to do business in this State, for which such person is required to make a federal income tax return, regardless of whether such person is liable for a tax imposed by this Act.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/IL/bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K502.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.filing_rule.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/502(a)",
          "quote": "(a) In general. A return with respect to the taxes imposed by this Act shall be made by every person for any taxable year: (1) for which such person is liable for a tax imposed by this Act, or (2) in the case of a resident or in the case of a corporation which is qualified to do business in this State, for which such person is required to make a federal income tax return, regardless of whether such person is liable for a tax imposed by this Act.",
          "role": "general_return_requirement",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/IL/bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c.html",
          "source_sha256": "bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K502.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(p)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) For taxable years ending on or after December 31, 2021 and beginning prior to January 1, 2026, a partnership (other than a publicly traded partnership under Section 7704 of the Internal Revenue Code) or Subchapter S corporation may elect to apply the provisions of this subsection. A separate election shall be made for each taxable year. Such election shall be made at such time, and in such form and manner as prescribed by the Department, and, once made, is irrevocable.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.filing_rule.personal_property_tax_replacement_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/502(e), current-period sentence",
          "quote": "For taxable years ending on or after December 31, 1993, taxpayers that are corporations (other than Subchapter S corporations) and that are members of the same unitary business group shall be treated as one taxpayer for purposes of any original return, amended return which includes the same taxpayers of the unitary group which joined in filing the original return, extension, claim for refund, assessment, collection and payment and determination of the group's tax liability under this Act.",
          "role": "unitary_group_return_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/IL/bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c.html",
          "source_sha256": "bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K502.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/502(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) In general. A return with respect to the taxes imposed by this Act shall be made by every person for any taxable year: (1) for which such person is liable for a tax imposed by this Act, or (2) in the case of a resident or in the case of a corporation which is qualified to do business in this State, for which such person is required to make a federal income tax return, regardless of whether such person is liable for a tax imposed by this Act.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/IL/bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bb38f50b8551a506f0f0b95bebc4ef9a9617ebc8b9c8a7156ce0a0a67134190c",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K502.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.tax_regime.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(b)(14)",
          "quote": "(14) In the case of a corporation, for taxable years beginning on or after July 1, 2017, an amount equal to 7% of the taxpayer's net income for the taxable year.",
          "role": "current_corporate_rate",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
          "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Illinois imposes a net-income tax on corporations; the current corporate rate provision applies to taxable years beginning on or after July 1, 2017.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) In general. A tax measured by net income is hereby imposed on every individual, corporation, trust and estate for each taxable year ending after July 31, 1969 on the privilege of earning or receiving income in or as a resident of this State. Such tax shall be in addition to all other occupation or privilege taxes imposed by this State or by any municipal corporation or political subdivision thereof.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.tax_regime.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(p)(1)",
          "quote": "(1) For taxable years ending on or after December 31, 2021 and beginning prior to January 1, 2026, a partnership (other than a publicly traded partnership under Section 7704 of the Internal Revenue Code) or Subchapter S corporation may elect to apply the provisions of this subsection. A separate election shall be made for each taxable year. Such election shall be made at such time, and in such form and manner as prescribed by the Department, and, once made, is irrevocable.",
          "role": "election_and_period",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
          "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Within the stated taxable-year window, an electing partnership or S corporation is subject to Illinois PTE tax at the entity level.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(p)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) Entity-level tax. A partnership or Subchapter S corporation electing to apply the provisions of this subsection shall be subject to a tax for the privilege of earning or receiving income in this State in an amount equal to 4.95% of the taxpayer's net income for the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.tax_regime.personal_property_tax_replacement_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/201(d)",
          "quote": "(d) Additional Personal Property Tax Replacement Income Tax Rates. The personal property tax replacement income tax imposed by this subsection and subsection (c) of this Section in the case of a corporation, other than a Subchapter S corporation and except as adjusted by subsection (d-1), shall be an additional amount equal to 2.85% of such taxpayer's net income for the taxable year, except that beginning on January 1, 1981, and thereafter, the rate of 2.85% specified in this subsection shall be reduced to 2.5%, and in the case of a partnership, trust or a Subchapter S corporation shall be an additional amount equal to 1.5% of such taxpayer's net income for the taxable year.",
          "role": "replacement_tax_rates",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
          "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Illinois imposes the Personal Property Tax Replacement Income Tax, measured by net income, on every stated corporation, partnership, and trust.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Personal Property Tax Replacement Income Tax. Beginning on July 1, 1979 and thereafter, in addition to such income tax, there is also hereby imposed the Personal Property Tax Replacement Income Tax measured by net income on every corporation (including Subchapter S corporations), partnership and trust, for each taxable year ending after June 30, 1979. Such taxes are imposed on the privilege of earning or receiving income in or as a resident of this State. The Personal Property Tax Replacement Income Tax shall be in addition to the income tax imposed by subsections (a) and (b) of this Section and in addition to all other occupation or privilege taxes imposed by this State or by any municipal corporation or political subdivision thereof.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.treatment.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/1501(a)(27)(C)(i)",
          "quote": "(C) Holding companies. (i) For purposes of this subparagraph, a \"holding company\" is a corporation (other than a corporation that is a financial organization under paragraph (8) of this subsection (a) of Section 1501 because it is a bank holding company under the provisions of the Bank Holding Company Act of 1956 (12 U.S.C. 1841, et seq.) or because it is owned by a bank or a bank holding company) that owns a controlling interest in one or more other taxpayers (\"controlled taxpayers\"); that, during the period that includes the taxable year and the 2 immediately preceding taxable years or, if the corporation was formed during the current or immediately preceding taxable year, the taxable years in which the corporation has been in existence, derived substantially all its gross income from dividends, interest, rents, royalties, fees or other charges received from controlled taxpayers for the provision of services, and gains on the sale or other disposition of interests in controlled taxpayers or in property leased or licensed to controlled taxpayers or used by the taxpayer in providing services to controlled taxpayers; and that incurs no substantial expenses other than expenses (including interest and other costs of borrowing) incurred in connection with the acquisition and holding of interests in controlled taxpayers and in the provision of services to controlled taxpayers or in the leasing or licensing of property to controlled taxpayers.",
          "role": "holding_treatment_definition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
          "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html"
        },
        {
          "pinpoint": "35 ILCS 5/1501(a)(27)(C)(iii)",
          "quote": "(iii) A holding company shall apportion its business income under the subsection of Section 304 used by the other members of its unitary business group. The apportionment factors of a holding company which would be a member of more than one unitary business group shall be included with the apportionment factors of each unitary business group of which it is a member on a pro rata basis using the same method used in clause (ii).",
          "role": "holding_treatment_apportionment",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
          "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/1501(a)(27)(C)(ii)-(iii)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(ii) The income of a holding company which is a member of more than one unitary business group shall be included in each unitary business group of which it is a member on a pro rata basis, by including in each unitary business group that portion of the base income of the holding company that bears the same proportion to the total base income of the holding company as the gross receipts of the unitary business group bears to the combined gross receipts of all unitary business groups (in both cases without regard to the holding company) or on any other reasonable basis, consistently applied.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.treatment.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "An electing partnership that owns an interest in another electing partnership subtracts its distributive share of the lower-tier electing partnership's net income.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/201(p)(3)(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(B) Special rule for tiered partnerships. If a taxpayer making the election under paragraph (1) is a partner of another taxpayer making the election under paragraph (1), net income shall be computed as provided in subparagraph (A), except that the taxpayer shall subtract its distributive share of the net income of the electing partnership (including its distributive share of the net income of the electing partnership derived as a distributive share from electing partnerships in which it is a partner).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-201-income-pte-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "605b67c3cc09bd8fe7bd3cd1d4ae89448a265010f39ef80079fdc00a81288575",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IL.llc.treatment.personal_property_tax_replacement_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "35 ILCS 5/1501(a)(27)(C)(i)",
          "quote": "(C) Holding companies. (i) For purposes of this subparagraph, a \"holding company\" is a corporation (other than a corporation that is a financial organization under paragraph (8) of this subsection (a) of Section 1501 because it is a bank holding company under the provisions of the Bank Holding Company Act of 1956 (12 U.S.C. 1841, et seq.) or because it is owned by a bank or a bank holding company) that owns a controlling interest in one or more other taxpayers (\"controlled taxpayers\"); that, during the period that includes the taxable year and the 2 immediately preceding taxable years or, if the corporation was formed during the current or immediately preceding taxable year, the taxable years in which the corporation has been in existence, derived substantially all its gross income from dividends, interest, rents, royalties, fees or other charges received from controlled taxpayers for the provision of services, and gains on the sale or other disposition of interests in controlled taxpayers or in property leased or licensed to controlled taxpayers or used by the taxpayer in providing services to controlled taxpayers; and that incurs no substantial expenses other than expenses (including interest and other costs of borrowing) incurred in connection with the acquisition and holding of interests in controlled taxpayers and in the provision of services to controlled taxpayers or in the leasing or licensing of property to controlled taxpayers.",
          "role": "holding_treatment_definition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
          "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html"
        },
        {
          "pinpoint": "35 ILCS 5/1501(a)(27)(C)(iii)",
          "quote": "(iii) A holding company shall apportion its business income under the subsection of Section 304 used by the other members of its unitary business group. The apportionment factors of a holding company which would be a member of more than one unitary business group shall be included with the apportionment factors of each unitary business group of which it is a member on a pro rata basis using the same method used in clause (ii).",
          "role": "holding_treatment_apportionment",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
          "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
          "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "35 ILCS 5/1501(a)(27)(C)(ii)-(iii)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(ii) The income of a holding company which is a member of more than one unitary business group shall be included in each unitary business group of which it is a member on a pro rata basis, by including in each unitary business group that portion of the base income of the holding company that bears the same proportion to the total base income of the holding company as the gross receipts of the unitary business group bears to the combined gross receipts of all unitary business groups (in both cases without regard to the holding company) or on any other reasonable basis, consistently applied.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IL/snapshots/il-stat-35-5-1501-tax-definitions.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "0eb86474305c0a438f6f75d725a535d2728820fda51b68e8e048e5ff6b491e80",
      "source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.base_tax_locator.corporate_adjusted_gross_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Ind. Code § 6-3-2-1(c)",
          "quote": "(c) Except as provided in section 1.5 of this chapter (before its expiration), each taxable year, a tax at the following rate of adjusted gross income is imposed on that part of the adjusted gross income derived from sources within Indiana of every corporation: […] (11) After June 30, 2021, four and nine-tenths percent (4.9%).",
          "role": "corporate rate locator",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
          "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
          "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf"
        },
        {
          "pinpoint": "Ind. Code § 6-3-2-12",
          "quote": "Sec. 12. (a) As used in this section, the term \"foreign source dividend\" means a dividend from a foreign corporation. The term: (1) includes any amount that a taxpayer is required to include in its gross income for a taxable year under Sections 951 and 951A of the Internal Revenue Code, and, for taxable years beginning after December 25, 2016, any amounts required to be included in adjusted gross income under this article after application of IC 6-3-1-3.5(b)(13), IC 6-3-1-3.5(d)(12), and IC 6-3-1-3.5(e)(12), but prior to application of this section; and (2) does not include any amount that is treated as a dividend under Section 78 of the […] Internal Revenue Code. The reference in subdivision (1) to amounts required to be included in adjusted gross income under this article after application of IC 6-3-1-3.5(b)(13), IC 6-3-1-3.5(d)(12), and IC 6-3-1-3.5(e)(12) applies in the same taxable year that the taxpayer takes into account the increase in Subpart F income as a result of Section 965(a) of the Internal Revenue Code and uses the deduction for deferred foreign income under Section 965(c) of the Internal Revenue Code. (b) A corporation that includes any foreign source dividend in its adjusted gross income for a taxable year is entitled to a deduction from that adjusted gross income. The amount of the deduction equals the product of: (1) the amount of the foreign source dividend included in the corporation's adjusted gross income for the taxable year; multiplied by (2) the percentage prescribed in subsection (c), (d), or (e), as the case may be. (c) The percentage referred to in subsection (b)(2) is one hundred percent (100%) if the corporation that includes the foreign source dividend in its adjusted gross income owns stock possessing at least eighty percent (80%) of the total combined voting power of all classes of stock of the foreign corporation from which the dividend is derived. (d) The percentage referred to in subsection (b)(2) is eighty-five percent (85%) if the corporation that includes the foreign source dividend in its adjusted gross income owns stock possessing at least fifty percent (50%) but less than eighty percent (80%) of the total combined voting power of all classes of stock of the foreign corporation from which the dividend is derived. (e) The percentage referred to in subsection (b)(2) is fifty percent (50%) if the corporation that includes the foreign source dividend in its adjusted gross income owns stock possessing less than fifty percent (50%) of the total combined voting power of all classes of stock of the foreign corporation from which the dividend is derived.",
          "role": "foreign-source-dividend deduction",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
          "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
          "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate adjusted-gross-income base, rate, and foreign-source-dividend deduction are located in the cited sections.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code § 6-3-1-3.5(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) In the case of corporations, the same as \"taxable income\" (as defined in Section 63 of the Internal Revenue Code) adjusted as follows: (1) Subtract income that is exempt from taxation under this article by the Constitution and statutes of the United States. (2) Add an amount equal to any deduction or deductions allowed or allowable pursuant to Section 170 of the Internal Revenue Code (concerning charitable contributions). (3) Except as provided in subsection (c), add an amount equal to any deduction or deductions allowed or allowable pursuant to Section 63 of the Internal Revenue Code for taxes based on or measured by income and levied at the state level by any state of the United States. (4) Subtract an amount equal to the amount included in the corporation's taxable income under Section 78 of the Internal Revenue Code (concerning foreign tax credits).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Ind. Code § 6-3-2.1-4(b)",
          "quote": "(b) The tax rate shall be the tax rate specified in IC 6-3-2-1(a) (before July 1, 2025) or IC 6-3-2-1(b) (after June 30, 2025) as of the last day of the electing entity's taxable year, and the tax shall be due on the same date as the entity return for the taxable year is due under this article, without regard to extensions.",
          "role": "rate and due-date locator",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
          "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
          "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective pass-through-entity tax base, allocation method, rate, and due-date locators are in Ind. Code § 6-3-2.1-4(a)-(b).",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code § 6-3-2.1-4(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 4. (a) A tax shall be imposed on the adjusted gross income of an electing entity for the taxable year of the election. The adjusted gross income of the electing entity shall be the aggregate of the direct owners' share of the electing entity's adjusted gross income. For purposes of this section: (1) the electing entity shall determine each nonresident direct owner's share after allocation and apportionment pursuant to IC 6-3-2-2; and (2) the electing entity shall determine the resident direct owner's share either: (A) before allocation and apportionment pursuant to IC 6-3-2-2; or (B) after allocation and apportionment pursuant to IC 6-3-2-2. The electing entity must use the same method for all resident direct owners.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.does_not_reach.corporate_adjusted_gross_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The deduction is confined by definition to dividends from a foreign corporation.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code § 6-3-2-12(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 12. (a) As used in this section, the term \"foreign source dividend\" means a dividend from a foreign corporation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The special allocation excludes the stated security-interest income and yields to business-income treatment for integrally related, operational, or working-capital investment activity.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code §§ 6-3-1-43, 6-3-2-3.3(b)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 43. The term \"qualifying investment partnership income\" means the adjusted gross income from qualifying investment securities, excluding any income or loss from an asset described in section 42(13) of this chapter. […] (2) any qualifying investment partnership income that is distributable to a nonresident partner shall be treated as business income and apportioned as if such income had been received directly by the partner if such income is from investment activity: (A) that is directly or integrally related to any other business activity conducted in this state by the nonresident partner (or another corporation or entity that is unitary with the partner); (B) that serves an operational function to any other business activity of the nonresident partner (or another corporation or entity that is unitary with the partner); or (C) where assets of the investment partnership were acquired with working capital from a trade or business activity conducted in this state in which the nonresident partner (or another corporation or entity that is unitary with the partner) owns an interest.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.effective_period.corporate_adjusted_gross_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current corporate adjusted gross income tax rate applies after June 30, 2021.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code § 6-3-2-1(c)(11)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(11) After June 30, 2021, four and nine-tenths percent (4.9%).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The PTET chapter applies after 2021; the investment-partnership allocation rule applies to taxable years beginning after December 31, 2025.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code §§ 6-3-2.1-1, 6-3-2-3.3(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 1. This chapter applies to taxable years beginning after December 31, 2021. […] (b) For all taxable years beginning after December 31, 2025, in the case of an investment partnership:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.filing_rule.corporate_adjusted_gross_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Every corporation with Indiana-source gross income files a return; the statute states the applicable fourth- or fifth-month due-date rule.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code §§ 6-3-4-1(3), 6-3-4-3(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) Every corporation having for the taxable year any gross income from sources within the state of Indiana. […] Sec. 3. (a) Returns required to be made pursuant to section 1 of this chapter shall be filed with the department on or before the later of the following: (1) The 15th day of the fourth month following the close of the taxable year. (2) For a corporation whose federal tax return is due on or after the date set forth in subdivision (1), as determined without regard to any extensions, Saturdays, Sundays, or holidays recognized by the Internal Revenue Service, the 15th day of the fifth month following the close of the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code § 6-3-2.1-4(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) On its return for the taxable year, the electing entity shall attach a schedule showing the calculation of the tax and the credit for each direct owner, and remit the tax with the return, taking into account prior estimated tax payments and other tax payments by the electing entity, along with other payments that are credited to the electing entity as tax paid under this chapter or as tax withheld under IC 6-3-4 or IC 6-5.5-2-8. The department may prescribe the form for providing the information required by this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.tax_regime.corporate_adjusted_gross_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Ind. Code § 6-3-1-10",
          "quote": "Sec. 10. As used in this article, \"corporation\" includes all corporations, associations, real estate investment trusts (as defined in the Internal Revenue Code), joint stock companies, whether organized for profit or not-for-profit, any receiver, trustee or conservator thereof, business trusts, Massachusetts trusts, any proprietorship or partnership taxable under Section 1361 of the Internal Revenue Code, and any publicly traded partnership that is treated as a corporation for federal income tax purposes under Section 7704 of the Internal Revenue Code. The term includes life insurance companies (as defined in Section 816(a) of the Internal Revenue Code) and insurance companies subject to tax under Section 831 of the Internal Revenue Code.",
          "role": "corporation definition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
          "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
          "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code §§ 6-3-1-10, 6-3-2-1(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Except as provided in section 1.5 of this chapter (before its expiration), each taxable year, a tax at the following rate of adjusted gross income is imposed on that part of the adjusted gross income derived from sources within Indiana of every corporation: […] (11) After June 30, 2021, four and nine-tenths percent (4.9%).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Ind. Code § 6-3-2.1-2(1)",
          "quote": "Sec. 2. The following definitions apply throughout this chapter: (1) \"Electing entity\" means a pass through entity described in IC 6-3-1-35 that is subject to Subchapter K or Subchapter S of the Internal Revenue Code and makes the election under this chapter.",
          "role": "electing-entity definition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
          "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
          "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf"
        },
        {
          "pinpoint": "Ind. Code § 6-3-2.1-3(b)",
          "quote": "(b) Each taxable year, an authorized person may elect, on behalf of the electing entity, to have the adjusted gross income tax under IC 6-3-1 through IC 6-3-7 imposed upon the […] electing entity. The entity owners shall remain liable for adjusted gross income tax under IC 6-3-1 through IC 6-3-7 on their share of the electing entity's adjusted gross income but with the credit provided to the entity owners as set forth in section 5 of this chapter.",
          "role": "annual election",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
          "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
          "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code §§ 6-3-2.1-2(1), 6-3-2.1-3(b), 6-3-2.1-4(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 4. (a) A tax shall be imposed on the adjusted gross income of an electing entity for the taxable year of the election. The adjusted gross income of the electing entity shall be the aggregate of the direct owners' share of the electing entity's adjusted gross income. For purposes of this section: (1) the electing entity shall determine each nonresident direct owner's share after allocation and apportionment pursuant to IC 6-3-2-2; and (2) the electing entity shall determine the resident direct owner's share either: (A) before allocation and apportionment pursuant to IC 6-3-2-2; or (B) after allocation and apportionment pursuant to IC 6-3-2-2. The electing entity must use the same method for all resident direct owners.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.treatment.corporate_adjusted_gross_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A corporation-classified LLC remains within corporate adjusted gross income tax, while qualifying foreign-source dividends receive the ownership-tiered statutory deduction.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code § 6-3-2-12(a)-(e)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 12. (a) As used in this section, the term \"foreign source dividend\" means a dividend from a foreign corporation. The term: (1) includes any amount that a taxpayer is required to include in its gross income for a taxable year under Sections 951 and 951A of the Internal Revenue Code, and, for taxable years beginning after December 25, 2016, any amounts required to be included in adjusted gross income under this article after application of IC 6-3-1-3.5(b)(13), IC 6-3-1-3.5(d)(12), and IC 6-3-1-3.5(e)(12), but prior to application of this section; and (2) does not include any amount that is treated as a dividend under Section 78 of the […] Internal Revenue Code. The reference in subdivision (1) to amounts required to be included in adjusted gross income under this article after application of IC 6-3-1-3.5(b)(13), IC 6-3-1-3.5(d)(12), and IC 6-3-1-3.5(e)(12) applies in the same taxable year that the taxpayer takes into account the increase in Subpart F income as a result of Section 965(a) of the Internal Revenue Code and uses the deduction for deferred foreign income under Section 965(c) of the Internal Revenue Code. (b) A corporation that includes any foreign source dividend in its adjusted gross income for a taxable year is entitled to a deduction from that adjusted gross income. The amount of the deduction equals the product of: (1) the amount of the foreign source dividend included in the corporation's adjusted gross income for the taxable year; multiplied by (2) the percentage prescribed in subsection (c), (d), or (e), as the case may be. (c) The percentage referred to in subsection (b)(2) is one hundred percent (100%) if the corporation that includes the foreign source dividend in its adjusted gross income owns stock possessing at least eighty percent (80%) of the total combined voting power of all classes of stock of the foreign corporation from which the dividend is derived. (d) The percentage referred to in subsection (b)(2) is eighty-five percent (85%) if the corporation that includes the foreign source dividend in its adjusted gross income owns stock possessing at least fifty percent (50%) but less than eighty percent (80%) of the total combined voting power of all classes of stock of the foreign corporation from which the dividend is derived. (e) The percentage referred to in subsection (b)(2) is fifty percent (50%) if the corporation that includes the foreign source dividend in its adjusted gross income owns stock possessing less than fifty percent (50%) of the total combined voting power of all classes of stock of the foreign corporation from which the dividend is derived.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#IN.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Ind. Code § 6-3-2.1-4(a)(1)",
          "quote": "Sec. 4. (a) A tax shall be imposed on the adjusted gross income of an electing entity for the taxable year of the election. The adjusted gross income of the electing entity shall be the aggregate of the direct owners' share of the electing entity's adjusted gross income. For purposes of this section: (1) the electing entity shall determine each nonresident direct owner's share after allocation and apportionment pursuant to IC 6-3-2-2; and (2) the electing entity shall determine the resident direct owner's share either: (A) before allocation and apportionment pursuant to IC 6-3-2-2; or (B) after allocation and apportionment pursuant to IC 6-3-2-2. The electing entity must use the same method for all resident direct owners.",
          "role": "PTET nonresident-owner base cross-reference",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
          "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
          "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Ind. Code § 6-3-2-3.3",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 3.3. (a) As used in this section, \"nonresident partner\" has the meaning set forth in IC 6-3-4-12(n). (b) For all taxable years beginning after December 31, 2025, in the case of an investment partnership: (1) any qualifying investment partnership income that is distributable to a nonresident partner shall be allocated to the partner's state of residence (in the case of an individual, estate, or trust) or commercial domicile (in the case of any corporation or other entity) for purposes of section 2 of this chapter; and (2) any qualifying investment partnership income that is distributable to a nonresident partner shall be treated as business income and apportioned as if such income had been received directly by the partner if such income is from investment activity: (A) that is directly or integrally related to any other business activity conducted in this state by the nonresident partner (or another corporation or entity that is unitary with the partner); (B) that serves an operational function to any other business activity of the nonresident partner (or another corporation or entity that is unitary with the partner); or (C) where assets of the investment partnership were acquired with working capital from a trade or business activity conducted in this state in which the nonresident partner (or another corporation or entity that is unitary with the partner) owns an interest. (c) For purposes of this section, the following apply: (1) If an entity is permitted to allocate qualifying investment partnership income under subsection (b)(1), the entity shall exclude the receipts derived from the investment […] partnership and attributable to the investment partnership income from the denominator of the sales factor in section 2(e) of this chapter. (2) If an entity is required to treat qualifying investment partnership income as apportionable income, the entity's share of receipts from the investment partnership and attributable to the investment partnership shall be included in the denominator of the sales factor and attributed to the entity's state of domicile for purposes of section 2(e) of this chapter. (3) For purposes of subsection (b)(2), a corporation or other entity shall be treated as unitary with the partner if the partner and the corporation or other entity would be required to be included in a combined income tax return under this article, determined as if all relevant entities are subject to tax under this article as corporations and are not corporations described in section 2.4 of this chapter. However, in the case of a partner and a corporate partnership, a unitary relationship shall be determined without regard to the corporate partner's percentage of ownership of the partnership. (4) Nothing in this section shall affect the apportionment and allocation of income and receipts derived from partnerships other than qualified investment partnership income from investment partnerships.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/IN/snapshots/c50/IN/d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d994653a1d1c1c78ee79162aafa63beb32b0b05596f1cf4002a60ef77379d314",
      "source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The Kansas corporate income-tax base and rates are located at K.S.A. 79-32,110b(c).",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,110b(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The normal tax shall be in an amount equal to 4% of the Kansas taxable income of such corporation; and (2) the surtax shall be in an amount equal to 3% of the Kansas taxable income of such corporation in excess of $50,000.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/ks-stat-79-32-110b-income-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d2b5d412c534aa1c12f41c83b090dccdb935e9dab35a8d28d3bcf5581dc4bb18",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0110b_section/079_032_0110b_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The elective pass-through entity tax base and rate locator is K.S.A. 79-32,287(a).",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,287(a)–(f), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to any taxable period for which it has made the election under K.S.A. 2025 Supp. 79-32,286, and amendments thereto, an electing pass-through entity shall be subject to a tax in an amount equal to the highest rate of tax for the applicable income tax year under K.S.A. 79-32,110(a), and amendments thereto, multiplied by the sum of:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/162c1468ee9b1712a1cd1ef8782e1c796f17fdb789c2f5136618e2d1e57e1145.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "162c1468ee9b1712a1cd1ef8782e1c796f17fdb789c2f5136618e2d1e57e1145",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,138(c)(v)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "80% of dividends from corporations incorporated outside of the United States or the District of Columbia which are included in federal taxable income. As used in this paragraph, \"dividends\" includes amounts included in income under section 965 of the federal internal revenue code of 1986, net of the deduction permitted by section 965(c) of the federal internal revenue code of 1986. For all taxable years commencing after December 31, 2020, this paragraph does not apply to amounts excluded from income pursuant to K.S.A. 79-32,117(c)(xxv), and amendments thereto, or amounts added back pursuant to K.S.A. 79-32,138(b)(vii), and amendments thereto; and",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/b46e37bec30bf060e337f8767084781aa0da612ee2a7fa75bb626e975b2e78e9.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b46e37bec30bf060e337f8767084781aa0da612ee2a7fa75bb626e975b2e78e9",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0138_section/079_032_0138_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "For a partnership, the statutory definition of electing pass-through entity owner excludes a C corporation partner.",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,285(c), (d), (g), and (h)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "\"Electing pass-through entity owner\" means, with respect to an S corporation, a shareholder of the S corporation and, with respect to a partnership, a partner in the partnership, except that a partner does not include a C corporation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/0b25cbf20a60a7a0fdd877e7b2f5e1c0d1d2d6dc82c24f2067299d8baf7bf2b5.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "0b25cbf20a60a7a0fdd877e7b2f5e1c0d1d2d6dc82c24f2067299d8baf7bf2b5",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0285_section/079_032_0285_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,138(c)(v)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For all taxable years commencing after December 31, 2020, this paragraph does not apply to amounts excluded from income pursuant to K.S.A. 79-32,117(c)(xxv), and amendments thereto, or amounts added back pursuant to K.S.A. 79-32,138(b)(vii), and amendments thereto; and",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/b46e37bec30bf060e337f8767084781aa0da612ee2a7fa75bb626e975b2e78e9.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b46e37bec30bf060e337f8767084781aa0da612ee2a7fa75bb626e975b2e78e9",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0138_section/079_032_0138_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The entity-level tax provisions apply to taxable years commencing on or after January 1, 2022.",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,287(a)–(f), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The provisions of this section shall apply to taxable years commencing on or after January 1, 2022.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/162c1468ee9b1712a1cd1ef8782e1c796f17fdb789c2f5136618e2d1e57e1145.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "162c1468ee9b1712a1cd1ef8782e1c796f17fdb789c2f5136618e2d1e57e1145",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Kansas Department of Revenue, 2025 Corporate Income Tax Instructions, Who Must File a Return?",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A Kansas corporate income tax return must be filed by all corporations doing business in or deriving income from sources within Kansas who are required to file a federal income tax return, whether or not a tax is due.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/ks-revenue-corporate-income-tax-2025.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fef4e5a979d1968c75667646024d5b008720701dc7737f5fe3a92acdafafbc1d",
      "source_url": "https://www.ksrevenue.gov/corpbook25.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The S corporation or partnership makes the election on its filed return, and that filing binds all electing pass-through entity owners.",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,286, complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The S corporation or partnership shall make the election on the return filed by such S corporation or partnership under K.S.A. 79-3220 and 79-3221, and amendments thereto. The filing of such return shall be binding on all electing pass-through entity owners.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/ks-stat-79-32-286-pte-election.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "760e513f68cfd7f08419c70207503125e3f022c52b6997db39e528b9c6d9bbe6",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0286_section/079_032_0286_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.tax_regime.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Kansas Department of Revenue, Pub. KS-1216, Business Structure — Limited Liability Company",
          "quote": "The Limited Liability Company (LLC) is a business owned by one or more members. It has some aspects of a partnership and some of a corporation. Business income from a limited liability company may be taxed as a corporation or as a partnership. Limited liability companies must register with the Secretary of State.",
          "role": "llc_classification",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/dde0022ce14da1081e4bc8de45df5f189f10f8ee15afe961bd79a86a07e8e3c9.html",
          "source_sha256": "dde0022ce14da1081e4bc8de45df5f189f10f8ee15afe961bd79a86a07e8e3c9",
          "source_url": "https://www.ksrevenue.gov/pub1216.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Kansas imposes corporate income tax on every corporation doing business in Kansas or deriving income from Kansas sources.",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,110b(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax is hereby imposed upon the Kansas taxable income of every corporation doing business within this state or deriving income from sources within this state.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/ks-stat-79-32-110b-income-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d2b5d412c534aa1c12f41c83b090dccdb935e9dab35a8d28d3bcf5581dc4bb18",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0110b_section/079_032_0110b_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "K.S.A. 79-32,286, complete section",
          "quote": "Notwithstanding K.S.A. 79-32,129 and 79-32,139, and amendments thereto, and except as provided in subsection (b), for taxable years commencing on or after January 1, 2022, an S corporation or partnership may annually elect to be subject to tax at the entity level for the taxable period.",
          "role": "election",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/ks-stat-79-32-286-pte-election.html",
          "source_sha256": "760e513f68cfd7f08419c70207503125e3f022c52b6997db39e528b9c6d9bbe6",
          "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0286_section/079_032_0286_k/"
        },
        {
          "pinpoint": "K.S.A. 79-32,285(c), (d), (g), and (h)",
          "quote": "\"Electing pass-through entity\" means, with respect to a taxable period, an S corporation or partnership that has made the election under K.S.A. 2025 Supp. 79-32,286, and amendments thereto, with respect to the taxable period.",
          "role": "covered_entity_definition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/0b25cbf20a60a7a0fdd877e7b2f5e1c0d1d2d6dc82c24f2067299d8baf7bf2b5.html",
          "source_sha256": "0b25cbf20a60a7a0fdd877e7b2f5e1c0d1d2d6dc82c24f2067299d8baf7bf2b5",
          "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0285_section/079_032_0285_k/"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "An electing pass-through entity is subject to Kansas entity-level tax computed under K.S.A. 79-32,287(a).",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,287(a)–(f), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to any taxable period for which it has made the election under K.S.A. 2025 Supp. 79-32,286, and amendments thereto, an electing pass-through entity shall be subject to a tax in an amount equal to the highest rate of tax for the applicable income tax year under K.S.A. 79-32,110(a), and amendments thereto, multiplied by the sum of:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/162c1468ee9b1712a1cd1ef8782e1c796f17fdb789c2f5136618e2d1e57e1145.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "162c1468ee9b1712a1cd1ef8782e1c796f17fdb789c2f5136618e2d1e57e1145",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Qualifying foreign-corporation dividends receive an 80% subtraction from federal taxable income in computing Kansas corporate taxable income.",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,138(c)(v)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "80% of dividends from corporations incorporated outside of the United States or the District of Columbia which are included in federal taxable income. As used in this paragraph, \"dividends\" includes amounts included in income under section 965 of the federal internal revenue code of 1986, net of the deduction permitted by section 965(c) of the federal internal revenue code of 1986. For all taxable years commencing after December 31, 2020, this paragraph does not apply to amounts excluded from income pursuant to K.S.A. 79-32,117(c)(xxv), and amendments thereto, or amounts added back pursuant to K.S.A. 79-32,138(b)(vii), and amendments thereto; and",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/b46e37bec30bf060e337f8767084781aa0da612ee2a7fa75bb626e975b2e78e9.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b46e37bec30bf060e337f8767084781aa0da612ee2a7fa75bb626e975b2e78e9",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0138_section/079_032_0138_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KS.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Kansas Department of Revenue, Frequently Asked Questions About the SALT Parity Act",
          "quote": "Can a partnership or S Corporation that only has portfolio income (interest, dividends, capital gains on securities, etc.) make the Kansas pass-through entity election and pay the Kansas tax on the portfolio income at the pass-through entity level? Yes, the election could be made under the circumstances described above.",
          "role": "portfolio_income_guidance",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/ks-revenue-salt-faq.html",
          "source_sha256": "f6ec224fe0a6c0f3b60c56653f4eaeeae3f1dff5d28fba7c6f6bae6129dae980",
          "source_url": "https://www.ksrevenue.gov/faqs-SALT.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The SALT Parity Act states no separate holding- or passive-entity treatment.",
      "fetch_event_id": null,
      "pinpoint": "K.S.A. 79-32,287(a)–(f), complete section",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to any taxable period for which it has made the election under K.S.A. 2025 Supp. 79-32,286, and amendments thereto, an electing pass-through entity shall be subject to a tax in an amount equal to the highest rate of tax for the applicable income tax year under K.S.A. 79-32,110(a), and amendments thereto, multiplied by the sum of:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KS/snapshots/c50/KS/162c1468ee9b1712a1cd1ef8782e1c796f17fdb789c2f5136618e2d1e57e1145.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "162c1468ee9b1712a1cd1ef8782e1c796f17fdb789c2f5136618e2d1e57e1145",
      "source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.base_tax_locator.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The corporation income-tax rate is located at KRS 141.040(2).",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.040(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning on or after January 1, 2018, the rate of five percent (5%) of taxable net income shall apply.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/896e3521d534a81f07fc9f25ca52b57c599d08f343570e2d6e0d3f7d1100d085.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "896e3521d534a81f07fc9f25ca52b57c599d08f343570e2d6e0d3f7d1100d085",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=55419",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The elective PTE tax points to the tax under KRS 141.020; KRS 141.209(2)(a) is the incorporation locator.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.209(2)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) For taxable years beginning on or after January 1, 2022, an authorized person may elect annually, on behalf of the electing entity, to have the tax under KRS 141.020 imposed upon the electing entity and based upon the ordinary income and the separately stated items of income calculated under KRS 141.206. (b) 1.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.base_tax_locator.limited_liability_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The LLET base and rate are located at KRS 141.0401(2).",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.0401(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning on or after January 1, 2007, an annual limited liability entity tax shall be paid by every corporation and every limited liability pass-through entity doing business in Kentucky on all Kentucky gross receipts or Kentucky gross profits except as provided in this subsection. A small business exclusion from this tax shall be provided based on the reduction contained in this subsection. The tax shall be the greater of the amount computed under paragraph (b) of this subsection or one hundred seventy-five dollars ($175), regardless of the application of any tax credits provided under this chapter or any other provisions of the Kentucky Revised Statutes for which the business entity may qualify.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/30435dfe7b608447ce9a1208c679706caf6876d4fffa8213733ef96abcfbe078.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "30435dfe7b608447ce9a1208c679706caf6876d4fffa8213733ef96abcfbe078",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57941",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.does_not_reach.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The dividend exclusion is limited to dividend income; the same calculation expressly includes interest from sister-state obligations.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.039(1)(b)-(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) Exclude all dividend income; (c) Include interest income derived from obligations of sister states and political subdivisions thereof;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/KY/1922f01e5c9cda4b2874ee98f4224c8cad07e44472b845a0fdbc1e1db29860bb.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1922f01e5c9cda4b2874ee98f4224c8cad07e44472b845a0fdbc1e1db29860bb",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57915",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "KRS 141.206(14)(a), qualified investment partnership owner-level investment-income rule",
          "quote": "Nonresident individuals shall not be taxable on investment income distributed\nby a qualified investment partnership. For purposes of this subsection, a\n\"qualified investment partnership\" means a pass-through entity that, during\nthe taxable year, holds only investments that produce income that would not\nbe taxable to a nonresident individual if held or owned individually.",
          "role": "owner_level_investment_rule",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
          "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942"
        },
        {
          "pinpoint": "KRS 141.206(14)(b), qualified investment partnership scope; effect on the KRS 141.209 base is not stated",
          "quote": "(b) A qualified investment partnership shall be subject to all other provisions\n\f           relating to a pass-through entity under this section and shall not be subject to\n           the tax imposed under KRS 141.040 or 141.0401.",
          "role": "operative_exception_boundary",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
          "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942"
        },
        {
          "pinpoint": "KRS 141.209(2)(a)",
          "quote": "For taxable years beginning on or after January 1, 2022, an authorized person\nmay elect annually, on behalf of the electing entity, to have the tax under KRS\n141.020 imposed upon the electing entity and based upon the ordinary income\nand the separately stated items of income calculated under KRS 141.206.",
          "role": "statutory_elective_base",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede.pdf",
          "source_sha256": "a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 1",
          "quote": "KRS 141.209(2)(a) imposes the tax “based upon the ordinary",
          "role": "official_filing_instruction_line_1",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 2",
          "quote": "income and separately stated items of income calculated under",
          "role": "official_filing_instruction_line_2",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 3",
          "quote": "KRS 141.206.” These items include all items listed on the Kentucky",
          "role": "official_filing_instruction_line_3",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 4",
          "quote": "Schedule K-1 reporting distributable share income including, but",
          "role": "official_filing_instruction_line_4",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 5",
          "quote": "not limited to, interest income, dividend income, capital gains,",
          "role": "official_filing_instruction_line_5",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 6",
          "quote": "guaranteed payments, and rents.",
          "role": "official_filing_instruction_line_6",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        }
      ],
      "capture_date": "2026-10-05",
      "claim_type": "closest_official_passage_for_official_record_silent",
      "display": null,
      "fetch_event_id": null,
      "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2",
      "public_reason": "The official record does not state this",
      "publish_status": "typed_unknown",
      "quote": "KRS 141.209(2)(a) imposes the tax “based upon the ordinary\nincome and separately stated items of income calculated under\nKRS 141.206.” These items include all items listed on the Kentucky\nSchedule K-1 reporting distributable share income including, but\nnot limited to, interest income, dividend income, capital gains,\nguaranteed payments, and rents.",
      "readiness": "official_record_silent",
      "reason_code": "value_not_stated_in_source",
      "rendered": "badge",
      "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
      "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.does_not_reach.limited_liability_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.206(14)(a)-(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(14) (a) Nonresident individuals shall not be taxable on investment income distributed by a qualified investment partnership. For purposes of this subsection, a \"qualified investment partnership\" means a pass-through entity that, during the taxable year, holds only investments that produce income that would not be taxable to a nonresident individual if held or owned individually. (b) A qualified investment partnership shall be subject to all other provisions (15) (a) (b) relating to a pass-through entity under this section and shall not be subject to the tax imposed under KRS 141.040 or 141.0401.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.effective_period.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The current corporate gross- and net-income calculation in KRS 141.039 is effective July 15, 2026.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.039 effective line",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective: July 15, 2026",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/KY/1922f01e5c9cda4b2874ee98f4224c8cad07e44472b845a0fdbc1e1db29860bb.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1922f01e5c9cda4b2874ee98f4224c8cad07e44472b845a0fdbc1e1db29860bb",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57915",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "KRS 141.209 effective line",
          "quote": "Effective: March 31, 2023",
          "role": "statutory_effective_date",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede.pdf",
          "source_sha256": "a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The election applies to taxable years beginning on or after January 1, 2022; KRS 141.209 became effective March 31, 2023.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.209(2)(a) and effective line",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) For taxable years beginning on or after January 1, 2022, an authorized person may elect annually, on behalf of the electing entity, to have the tax under KRS 141.020 imposed upon the electing entity and based upon the ordinary income and the separately stated items of income calculated under KRS 141.206. (b) 1.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.effective_period.limited_liability_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The current qualified-investment-partnership provision in KRS 141.206 is effective July 15, 2026.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.206 effective line",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective: July 15, 2026",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.filing_rule.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Income returns are due April 15 for calendar-year taxpayers or the fifteenth day of the fourth month after a fiscal year closes.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.160(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "All returns of income for the preceding taxable year shall be made by April 15 in each year, except returns made on the basis of a fiscal year, which shall be made by the fifteenth day of the fourth month following the close of the fiscal year. Blank forms for returns of income shall be supplied by the department.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/5191d4a26f83d7795948912d0e3f70e1e8e09a4012d324ddabd3ac50da134623.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "5191d4a26f83d7795948912d0e3f70e1e8e09a4012d324ddabd3ac50da134623",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=29084",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.209(2)(b)-(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "All calculations for the return shall continue to be made as provided under KRS 141.206. 2. The election shall be made on a form prescribed by the department. (c) For taxable years beginning on or after January 1, 2023, the election may be made at any time during the taxable year or after the end of the taxable year, but not later than the: 1. Fifteenth day of the fourth month after the close of the taxable year; or 2. Fifteenth day of the tenth month after the close of the taxable year, if the return is filed under KRS 141.170.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.filing_rule.limited_liability_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "KRS 141.206(1)",
          "quote": "Every pass-through entity doing business in this state shall, on or before the fifteenth day of the fourth month following the close of its annual accounting period, file a copy of its federal tax return with the form prescribed and furnished by the department.",
          "role": "pte_filing_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
          "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "A qualified investment partnership remains subject to the other PTE provisions, including the annual federal-return-copy filing rule in KRS 141.206(1).",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.206(14)(b), (1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(14) (a) Nonresident individuals shall not be taxable on investment income distributed by a qualified investment partnership. For purposes of this subsection, a \"qualified investment partnership\" means a pass-through entity that, during the taxable year, holds only investments that produce income that would not be taxable to a nonresident individual if held or owned individually. (b) A qualified investment partnership shall be subject to all other provisions (15) (a) (b) relating to a pass-through entity under this section and shall not be subject to the tax imposed under KRS 141.040 or 141.0401.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.tax_regime.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "KRS 141.208(2)",
          "quote": "141.208 Treatment of limited liability companies. (1) (2) For the purposes of this section, \"limited liability company\" shall mean any company subject to the provisions of KRS Chapter 275. For taxable years beginning after December 31, 2004, and before January 1, 2007, a limited liability company shall file a Kentucky corporate income tax return and determine its Kentucky income tax liability as provided in KRS 141.040 regardless of the tax treatment elected for federal income tax purposes. For all other taxable years, a limited liability company shall be treated for Kentucky income tax purposes in the same manner as its tax treatment elected for federal income tax purposes. All other income tax issues not expressly addressed by the provisions of this chapter shall be treated in the same manner as the issues are treated for federal income tax purposes.",
          "role": "llc_federal_classification_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/KY/ad12f6cbaa20b183b1b7e3d7056ab211abc9d83412ed7897cddab64a1b83c572.pdf",
          "source_sha256": "ad12f6cbaa20b183b1b7e3d7056ab211abc9d83412ed7897cddab64a1b83c572",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=29093"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.040(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) Every corporation doing business in this state, except those corporations listed in paragraphs (a) and (b) of this subsection, shall pay for each taxable year a tax to be computed by the taxpayer on taxable net income at the rates specified in this section: (a) For taxable years beginning prior to January 1, 2021: 1. Financial institutions, as defined in KRS 136.500, except bankers banks organized under KRS 286.3-135; 2. Savings and loan associations organized under the laws of this state and under the laws of the United States and making loans to members only; 3. Banks for cooperatives; 4. Production credit associations; 5. Insurance companies, including farmers' or other mutual hail, cyclone, windstorm, or fire insurance companies, insurers, and reciprocal underwriters; 6. Corporations or other entities exempt under Section 501 of the Internal Revenue Code; 7. Religious, educational, charitable, or like corporations not organized or conducted for pecuniary profit; and 8. Corporations whose only owned or leased property located in this state is located at the premises of a printer with which it has contracted for printing, provided that: a. The property consists of the final printed product, or copy from which the printed product is produced; and b. The corporation has no individuals receiving compensation in this state as provided in KRS 141.120(8)(b); and (b) For taxable years beginning on or after January 1, 2021: 1. Insurance companies, including farmers' or other mutual hail, cyclone, windstorm, or fire insurance companies, insurers, and reciprocal underwriters; 2. Corporations or other entities exempt under Section 501 of the Internal Revenue Code; 3. Religious, educational, charitable, or like corporations not organized or conducted for pecuniary profit; 4. Corporations whose only owned or leased property located in this state is located at the premises of a printer with which it has contracted for printing, provided that: a. The property consists of the final printed product, or copy from which the printed product is produced; and b. The corporation has no individuals receiving compensation in this state as provided in KRS 141.120(8)(b); and 5. For taxable years beginning before January 1, 2027, a disaster response (2) (3) (4) business.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/896e3521d534a81f07fc9f25ca52b57c599d08f343570e2d6e0d3f7d1100d085.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "896e3521d534a81f07fc9f25ca52b57c599d08f343570e2d6e0d3f7d1100d085",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=55419",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.209(2)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) For taxable years beginning on or after January 1, 2022, an authorized person may elect annually, on behalf of the electing entity, to have the tax under KRS 141.020 imposed upon the electing entity and based upon the ordinary income and the separately stated items of income calculated under KRS 141.206. (b) 1.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.tax_regime.limited_liability_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Kentucky imposes annual LLET on every corporation and limited liability pass-through entity doing business in Kentucky, subject to stated exceptions.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.0401(2)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning on or after January 1, 2007, an annual limited liability entity tax shall be paid by every corporation and every limited liability pass-through entity doing business in Kentucky on all Kentucky gross receipts or Kentucky gross profits except as provided in this subsection. A small business exclusion from this tax shall be provided based on the reduction contained in this subsection. The tax shall be the greater of the amount computed under paragraph (b) of this subsection or one hundred seventy-five dollars ($175), regardless of the application of any tax credits provided under this chapter or any other provisions of the Kentucky Revised Statutes for which the business entity may qualify.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/30435dfe7b608447ce9a1208c679706caf6876d4fffa8213733ef96abcfbe078.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "30435dfe7b608447ce9a1208c679706caf6876d4fffa8213733ef96abcfbe078",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57941",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.treatment.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "A corporation-classified holding LLC remains within corporation income tax, but all dividend income is excluded from the Kentucky gross-income calculation.",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.039(1)(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) Exclude all dividend income;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/KY/1922f01e5c9cda4b2874ee98f4224c8cad07e44472b845a0fdbc1e1db29860bb.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1922f01e5c9cda4b2874ee98f4224c8cad07e44472b845a0fdbc1e1db29860bb",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57915",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "KRS 141.206(14)(a), qualified investment partnership owner-level investment-income rule",
          "quote": "Nonresident individuals shall not be taxable on investment income distributed\nby a qualified investment partnership. For purposes of this subsection, a\n\"qualified investment partnership\" means a pass-through entity that, during\nthe taxable year, holds only investments that produce income that would not\nbe taxable to a nonresident individual if held or owned individually.",
          "role": "owner_level_investment_rule",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
          "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942"
        },
        {
          "pinpoint": "KRS 141.206(14)(b), qualified investment partnership scope; effect on the KRS 141.209 base is not stated",
          "quote": "(b) A qualified investment partnership shall be subject to all other provisions\n\f           relating to a pass-through entity under this section and shall not be subject to\n           the tax imposed under KRS 141.040 or 141.0401.",
          "role": "operative_exception_boundary",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
          "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942"
        },
        {
          "pinpoint": "KRS 141.209(2)(a)",
          "quote": "For taxable years beginning on or after January 1, 2022, an authorized person\nmay elect annually, on behalf of the electing entity, to have the tax under KRS\n141.020 imposed upon the electing entity and based upon the ordinary income\nand the separately stated items of income calculated under KRS 141.206.",
          "role": "statutory_elective_base",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede.pdf",
          "source_sha256": "a823997a7e1cbd4a8f925239d45cbe58fbcf52b0c9c4dc9ff90f1a4ca9e93ede",
          "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 1",
          "quote": "KRS 141.209(2)(a) imposes the tax “based upon the ordinary",
          "role": "official_filing_instruction_line_1",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 2",
          "quote": "income and separately stated items of income calculated under",
          "role": "official_filing_instruction_line_2",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 3",
          "quote": "KRS 141.206.” These items include all items listed on the Kentucky",
          "role": "official_filing_instruction_line_3",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 4",
          "quote": "Schedule K-1 reporting distributable share income including, but",
          "role": "official_filing_instruction_line_4",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 5",
          "quote": "not limited to, interest income, dividend income, capital gains,",
          "role": "official_filing_instruction_line_5",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        },
        {
          "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2, text line 6",
          "quote": "guaranteed payments, and rents.",
          "role": "official_filing_instruction_line_6",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
          "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
          "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf"
        }
      ],
      "capture_date": "2026-10-05",
      "claim_type": "closest_official_passage_for_official_record_silent",
      "display": null,
      "fetch_event_id": null,
      "pinpoint": "Form 740-PTET(I) (10-23), page 2, Specific Instructions for Form 740-PTET, Line 2",
      "public_reason": "The official record does not state this",
      "publish_status": "typed_unknown",
      "quote": "KRS 141.209(2)(a) imposes the tax “based upon the ordinary\nincome and separately stated items of income calculated under\nKRS 141.206.” These items include all items listed on the Kentucky\nSchedule K-1 reporting distributable share income including, but\nnot limited to, interest income, dividend income, capital gains,\nguaranteed payments, and rents.",
      "readiness": "official_record_silent",
      "reason_code": "value_not_stated_in_source",
      "rendered": "badge",
      "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-KY/captures/6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f668647fcb49ca01cfffc51f799bcbf9307c11a4ff0472e4a3d0d86c3ed2598",
      "source_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#KY.llc.treatment.limited_liability_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "A holding LLC that meets the qualified-investment-partnership test is expressly not subject to LLET under KRS 141.206(14)(b).",
      "fetch_event_id": null,
      "pinpoint": "KRS 141.206(14)(b)",
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      "publish_status": "publish_ready",
      "quote": "(14) (a) Nonresident individuals shall not be taxable on investment income distributed by a qualified investment partnership. For purposes of this subsection, a \"qualified investment partnership\" means a pass-through entity that, during the taxable year, holds only investments that produce income that would not be taxable to a nonresident individual if held or owned individually. (b) A qualified investment partnership shall be subject to all other provisions (15) (a) (b) relating to a pass-through entity under this section and shall not be subject to the tax imposed under KRS 141.040 or 141.0401.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/KY/snapshots/c50/030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "030c7d62f8c679b2d995a40827c92c2fe50bff2c944bc0bbc2752dc18e21fd12",
      "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#LA.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporation income-tax rate is located in La. R.S. 47:287.12.",
      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.12",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning on or after January 1, 2025, the tax to be assessed, levied, collected, and paid upon the Louisiana taxable income of every corporation shall be computed at the rate of five and one-half percent.",
      "readiness": "ready",
      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/LA/snapshots/c50/LA/15ecd9aef7bacc5e5745e0c69978bbaf1efdf1a9181c51e5a188a0f5f953ff6d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "15ecd9aef7bacc5e5745e0c69978bbaf1efdf1a9181c51e5a188a0f5f953ff6d",
      "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=101674",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#LA.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective entity-level tax rate cross-reference is located in La. R.S. 47:287.732.2(B).",
      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.732.2(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "B. Notwithstanding any provision of law to the contrary, the tax on the Louisiana taxable income of every entity that makes the election pursuant to this Section shall be computed at the rate levied on individuals pursuant to the provisions of R.S. 47:32.",
      "readiness": "ready",
      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/LA/snapshots/c50/LA/98225da321c03497eb238209e7bdd7cd9e920cc80bf63e0d359b18b9272e54a7.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "98225da321c03497eb238209e7bdd7cd9e920cc80bf63e0d359b18b9272e54a7",
      "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#LA.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The stated holding-income deductions address dividends and interest; the interest provision separately addresses the controlled-corporation election.",
      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.738(F)(1)-(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "F. Deduction for interest and dividends. (1) Effective for taxable years beginning after December 31, 2005, there shall be allowed for each taxable year a deduction equal to the amount of dividends that would otherwise be included in gross income. (2) Effective for taxable years beginning after December 31, 2005, there shall be allowed for each taxable year a deduction equal to the amount of interest that would otherwise be included in gross income; however, a corporation may elect to pay tax on interest income from a corporation which is controlled by the former through ownership of fifty percent or more of the voting stock of the latter and to use the provisions of R.S. 47:287.93(A)(2).",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/LA/snapshots/c50/LA/4c21ca57882dc420f3d5926ae6c4e2c3d70b8935babed8a2fcca21bb23148087.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4c21ca57882dc420f3d5926ae6c4e2c3d70b8935babed8a2fcca21bb23148087",
      "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=101725",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#LA.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "An entity filing a composite partnership return under La. R.S. 47:201.1 cannot make the election for the same tax year.",
      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.732.2(F)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "F. Any entity filing a composite partnership return pursuant to R.S. 47:201.1 is prohibited from making the election pursuant to this Section for the same tax year.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/LA/snapshots/c50/LA/98225da321c03497eb238209e7bdd7cd9e920cc80bf63e0d359b18b9272e54a7.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#LA.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current rate provision applies to taxable years beginning on or after January 1, 2025.",
      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.12",
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      "publish_status": "publish_ready",
      "quote": "For taxable years beginning on or after January 1, 2025, the tax to be assessed, levied, collected, and paid upon the Louisiana taxable income of every corporation shall be computed at the rate of five and one-half percent.",
      "readiness": "ready",
      "reason_code": null,
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      "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=101674",
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    "holding_tax:pp-holding-entity-tax#LA.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The election applies for the elected taxable year and all succeeding taxable years until termination under the statute.",
      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.732.2(A)(3)",
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      "quote": "(3) The election shall be effective for the taxable year of the entity for which it is made and for all succeeding taxable years of the entity, until the election is terminated by the secretary or an application for prospective termination of the election is effective.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/LA/snapshots/c50/LA/98225da321c03497eb238209e7bdd7cd9e920cc80bf63e0d359b18b9272e54a7.html",
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      "source_class": "S1",
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      "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
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    "holding_tax:pp-holding-entity-tax#LA.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Every corporation subject to the tax must file a return stating gross-income items and allowed deductions and credits.",
      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.612",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every corporation subject to taxation under this Part shall make a return stating specifically the items of its gross income and the deductions and credits allowed under this Part.",
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      "additional_sources": [
        {
          "pinpoint": "La. R.S. 47:287.732.2(D)",
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      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.732.2(A)(2)",
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      "quote": "(2) The election shall be made in writing and may be made at any time during the preceding taxable year, or at any time during the taxable year and on or before the fifteenth day of the fourth month after the close of the taxable year. The secretary may treat an election made after the fifteenth day of the fourth month after the close of the taxable year as timely made for the taxable year if the secretary determines that there was reasonable cause for the failure to make the election timely.",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
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      "quote": "A. There shall be levied, collected, and paid for each taxable year a tax upon the Louisiana taxable income of corporations and other entities taxed as corporations for federal income tax purposes, which entities shall be considered to be corporations for the purposes of this Chapter only, other than insurance companies as hereinafter provided. B. Corporations shall be taxed on their Louisiana taxable income, except as otherwise exempted.",
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          "pinpoint": "La. R.S. 47:287.732.2(A)(1)",
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      "display": "Louisiana taxes the Louisiana taxable income of an entity making the pass-through election at the rate referenced for individuals.",
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      "quote": "B. Notwithstanding any provision of law to the contrary, the tax on the Louisiana taxable income of every entity that makes the election pursuant to this Section shall be computed at the rate levied on individuals pursuant to the provisions of R.S. 47:32.",
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      "display": "Dividends and interest otherwise included in gross income receive statutory deductions, subject to the controlled-corporation interest election stated in the provision.",
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      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "F. Deduction for interest and dividends. (1) Effective for taxable years beginning after December 31, 2005, there shall be allowed for each taxable year a deduction equal to the amount of dividends that would otherwise be included in gross income. (2) Effective for taxable years beginning after December 31, 2005, there shall be allowed for each taxable year a deduction equal to the amount of interest that would otherwise be included in gross income; however, a corporation may elect to pay tax on interest income from a corporation which is controlled by the former through ownership of fifty percent or more of the voting stock of the latter and to use the provisions of R.S. 47:287.93(A)(2).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/LA/snapshots/c50/LA/4c21ca57882dc420f3d5926ae6c4e2c3d70b8935babed8a2fcca21bb23148087.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4c21ca57882dc420f3d5926ae6c4e2c3d70b8935babed8a2fcca21bb23148087",
      "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=101725",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#LA.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "La. R.S. 47:287.732.2(E)",
          "quote": "E. Unless otherwise provided in this Section, the provisions of this Part shall apply to all entities making an election pursuant to this Section.",
          "role": "supporting",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/LA/snapshots/c50/LA/98225da321c03497eb238209e7bdd7cd9e920cc80bf63e0d359b18b9272e54a7.html",
          "source_sha256": "98225da321c03497eb238209e7bdd7cd9e920cc80bf63e0d359b18b9272e54a7",
          "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "La. R.S. 47:287.738(F)(1)-(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "F. Deduction for interest and dividends. (1) Effective for taxable years beginning after December 31, 2005, there shall be allowed for each taxable year a deduction equal to the amount of dividends that would otherwise be included in gross income. (2) Effective for taxable years beginning after December 31, 2005, there shall be allowed for each taxable year a deduction equal to the amount of interest that would otherwise be included in gross income; however, a corporation may elect to pay tax on interest income from a corporation which is controlled by the former through ownership of fifty percent or more of the voting stock of the latter and to use the provisions of R.S. 47:287.93(A)(2).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/LA/snapshots/c50/LA/4c21ca57882dc420f3d5926ae6c4e2c3d70b8935babed8a2fcca21bb23148087.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4c21ca57882dc420f3d5926ae6c4e2c3d70b8935babed8a2fcca21bb23148087",
      "source_url": "https://www.legis.la.gov/legis/Law.aspx?d=101725",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.base_tax_locator.corporate_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The corporate excise base, measures, and minimum are located in Chapter 63 §§ 30 and 39.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 39(a)-(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) An amount equal to the sum of:— (1) $2.60 per 1,000 upon the value of: (i) its tangible property as determined to be taxable under paragraph 7 of section 30 if a tangible property corporation; or (ii) its net worth as determined to be taxable under paragraph 8 of section 30 if an intangible property corporation; and (2)(i) For tax years beginning before January 1, 2010, 9.5 per cent of its net income determined to be taxable in accordance with this chapter; (ii) for tax years beginning on or after January 1, 2010, but before January 1, 2011, 8.75 per cent of its net income determined to be taxable in accordance with this chapter; (iii) for tax years beginning on or after January 1, 2011, but before January 1, 2012, 8.25 per cent of its net income determined to be taxable in accordance with this chapter; or (iv) for tax years beginning on or after January 1, 2012, 8.0 per cent of its net income determined to be taxable in accordance with this chapter. (b) $456. A business corporation shall not be subject to the income measure of tax under clause (2) of subsection (a) if it is engaged in the business of selling tangible personal property and taxation of that business corporation under this chapter is precluded by the constitution or laws of the United States, or would be so precluded except for the fact that the business corporation stored tangible personal property in a licensed public storage warehouse, but no portion of any warehouse which is owned or leased by a consignor or consignee of the tangible personal property shall be considered a licensed public warehouse. A business corporation exempt from the income measure of the excise under this paragraph pursuant to federal Public Law 86–272 shall be subject to the excise under clause (1) of subsection (a) or subsection (b), whichever is greater.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/d8070a087898fa5615bf4811e59d1dfb9cb3dd65459dd5ef55e45ad0c73ca851.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d8070a087898fa5615bf4811e59d1dfb9cb3dd65459dd5ef55e45ad0c73ca851",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section39",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.base_tax_locator.elective_pass_through_entity_excise": {
      "additional_sources": [
        {
          "pinpoint": "M.G.L. c. 63D, § 1",
          "quote": "''Qualified income taxable in Massachusetts'', the income of an eligible pass-through entity determined under chapter 62 allocable to a qualified member and included in the qualified member's Massachusetts taxable income under said chapter 62.",
          "role": "qualified_income_definition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/dc414b66d82c65383861ff3d4bf87925b7ac5e95ccfca7c0a6dd3fa95a018741.html",
          "source_sha256": "dc414b66d82c65383861ff3d4bf87925b7ac5e95ccfca7c0a6dd3fa95a018741",
          "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section1"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The qualified-income definition and elective excise measure are located in Chapter 63D §§ 1 and 2.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63D, § 2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Section 2. An eligible pass-through entity may elect to pay an excise on its qualified income taxable in Massachusetts at a rate of 5 per cent. A qualified member of an electing eligible pass-through entity shall be allowed a refundable credit against the tax imposed under this chapter. The credit shall be available to qualified members in an amount proportionate to each qualified member's share of the tax due and paid under this chapter by the eligible pass-through entity multiplied by 0.9. The credit shall be available for the member's taxable year in which the electing eligible pass-through entity's taxable year ends.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/33e72a50e664d1cbf923d42a57b096dd98732b38a1180e154cca9d595d538b84.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33e72a50e664d1cbf923d42a57b096dd98732b38a1180e154cca9d595d538b84",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section2",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.base_tax_locator.security_corporation_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The security-corporation gross-income definition and excise measure are located in Chapter 63 §§ 30 and 38B.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 38B(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Every financial institution or business corporation which is engaged exclusively in buying, selling, dealing in, or holding securities on its own behalf and not as a broker, except securities of a DISC, and is not a bank holding company under the Internal Revenue Code, as amended and in effect for the taxable year, and, which either applies to the commissioner to be classified as a security corporation before the end of the taxable year and is so classified, or has been so classified by the commissioner for a prior taxable year and such classification has not been revoked before the end of the taxable year, shall pay, on account of each taxable year, an excise equal to one and thirty-two one hundredths percent of the gross income, as defined in section thirty, received by such corporation during the taxable year or four hundred and fifty-six dollars, whichever is greater.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.does_not_reach.corporate_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The general § 39 excise does not reach a corporation that is taxable under the separate § 38B security-corporation excise.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 38B(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Any corporation taxable under this section shall not be subject to the excise imposed by section 2, 2B, 32D or 39.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.does_not_reach.elective_pass_through_entity_excise": {
      "additional_sources": [
        {
          "pinpoint": "M.G.L. c. 63D, § 1",
          "quote": "''Qualified income taxable in Massachusetts'', the income of an eligible pass-through entity determined under chapter 62 allocable to a qualified member and included in the qualified member's Massachusetts taxable income under said chapter 62.",
          "role": "qualified_income_definition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/dc414b66d82c65383861ff3d4bf87925b7ac5e95ccfca7c0a6dd3fa95a018741.html",
          "source_sha256": "dc414b66d82c65383861ff3d4bf87925b7ac5e95ccfca7c0a6dd3fa95a018741",
          "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section1"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63D, § 1, qualified member",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "''Qualified member'', a shareholder of an S corporation or a partner in a partnership, including a member of a limited liability company that is treated as an S corporation or partnership under section 1361 of the Code or section 7701 of the Code, that is a natural person or trust or estate subject to tax under section 10 of chapter 62; provided, however, that a qualified member may be a resident, nonresident or a part-year resident.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/dc414b66d82c65383861ff3d4bf87925b7ac5e95ccfca7c0a6dd3fa95a018741.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "dc414b66d82c65383861ff3d4bf87925b7ac5e95ccfca7c0a6dd3fa95a018741",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section1",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.does_not_reach.security_corporation_excise": {
      "additional_sources": [
        {
          "pinpoint": "M.G.L. c. 63, § 38B(a)",
          "quote": "(a) Every financial institution or business corporation which is engaged exclusively in buying, selling, dealing in, or holding securities on its own behalf and not as a broker, except securities of a DISC, and is not a bank holding company under the Internal Revenue Code, as amended and in effect for the taxable year, and, which either applies to the commissioner to be classified as a security corporation before the end of the taxable year and is so classified, or has been so classified by the commissioner for a prior taxable year and such classification has not been revoked before the end of the taxable year, shall pay, on account of each taxable year, an excise equal to one and thirty-two one hundredths percent of the gross income, as defined in section thirty, received by such corporation during the taxable year or four hundred and fifty-six dollars, whichever is greater.",
          "role": "other_exclusions",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
          "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
          "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 38B(d)",
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      "publish_status": "publish_ready",
      "quote": "(d) Ownership interest in a real estate investment trust which is a related member, as defined in section 31I, shall not be considered a security for the purposes of this section. A real estate investment trust shall have the same meaning as that contained in section 856 of the Code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
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      "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MA.llc.effective_period.corporate_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Section 39 states the current income-measure period as tax years beginning on or after January 1, 2012.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 39(a)(2)(iv)",
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      "publish_status": "publish_ready",
      "quote": "(iv) for tax years beginning on or after January 1, 2012, 8.0 per cent of its net income determined to be taxable in accordance with this chapter.",
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      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section39",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MA.llc.effective_period.elective_pass_through_entity_excise": {
      "additional_sources": [
        {
          "pinpoint": "M.G.L. c. 63D, § 1 editorial effective note",
          "quote": "[Text of section effective for tax years beginning on or after January 1, 2021. See 2021, 69, Sec. 2.]",
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          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/dc414b66d82c65383861ff3d4bf87925b7ac5e95ccfca7c0a6dd3fa95a018741.html",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63D, § 3",
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      "quote": "Section 3. This chapter shall not apply to any taxable year for which the federal limitation on the state and local tax deduction imposed by section 164(b)(6) of the Internal Revenue Code of the United States, as amended and in effect for the applicable year, has expired or is otherwise not in effect.",
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    "holding_tax:pp-holding-entity-tax#MA.llc.effective_period.security_corporation_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No special commencement or sunset period was located for the § 38B security-corporation classification or excise in the complete Chapter 63 search.",
      "fetch_event_id": null,
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    "holding_tax:pp-holding-entity-tax#MA.llc.filing_rule.corporate_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
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      "pinpoint": "M.G.L. c. 62C, § 11",
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      "quote": "Section 11. Except as otherwise provided in this chapter, every business corporation, as defined in section 30 of chapter 63, shall file a return providing such information as the commissioner deems necessary for the determination of the taxes imposed upon it by said chapter 63. Except as otherwise provided in this chapter, an S corporation, as defined under section 1361 of the Internal Revenue Code, as amended and in effect for the taxable year, shall file a return on or before the fifteenth day of the third month following the close of each taxable year, and any other business corporation shall file a return on or before the fifteenth day of the fourth month following the close of each taxable year. The filing of a combined report pursuant to section 32B of chapter 63 in the manner prescribed by the commissioner shall satisfy the filing requirements of this section for any business corporation that, pursuant to such combined report, calculates and reports its own individual corporate excise liability based on the income and non-income measures of the corporate excise or minimum excise tax as applicable under section 32D or 39 of said chapter 63. A combined report shall not constitute a filing under this section for any business corporation that does not calculate and report its own individual corporate excise liability under said sections 32D and 39 of said chapter 63, whether or not such business corporation's income, sales or other attributes may be taken into account in the calculation of the excise under this chapter of an affiliated corporation that does calculate and report an individual corporate excise pursuant to such combined report.",
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    "holding_tax:pp-holding-entity-tax#MA.llc.filing_rule.elective_pass_through_entity_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63D, § 4",
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      "quote": "Section 4. The excise under this chapter shall be in addition to, and not in lieu of, any other Massachusetts tax required to be paid, including tax imposed by chapter 62 or chapter 63. The excise under this chapter shall be due and payable on the eligible pass-through entity's original, timely-filed return. A return that reports the excise shall be due at the same time as a partnership information return or corporate excise return would be due for the entity under chapter 62C. Nothing in this chapter shall alter any filing requirements for a qualified member under said chapter 62C.",
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      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.filing_rule.security_corporation_excise": {
      "additional_sources": [
        {
          "pinpoint": "M.G.L. c. 62C, § 11",
          "quote": "Section 11. Except as otherwise provided in this chapter, every business corporation, as defined in section 30 of chapter 63, shall file a return providing such information as the commissioner deems necessary for the determination of the taxes imposed upon it by said chapter 63. Except as otherwise provided in this chapter, an S corporation, as defined under section 1361 of the Internal Revenue Code, as amended and in effect for the taxable year, shall file a return on or before the fifteenth day of the third month following the close of each taxable year, and any other business corporation shall file a return on or before the fifteenth day of the fourth month following the close of each taxable year. The filing of a combined report pursuant to section 32B of chapter 63 in the manner prescribed by the commissioner shall satisfy the filing requirements of this section for any business corporation that, pursuant to such combined report, calculates and reports its own individual corporate excise liability based on the income and non-income measures of the corporate excise or minimum excise tax as applicable under section 32D or 39 of said chapter 63. A combined report shall not constitute a filing under this section for any business corporation that does not calculate and report its own individual corporate excise liability under said sections 32D and 39 of said chapter 63, whether or not such business corporation's income, sales or other attributes may be taken into account in the calculation of the excise under this chapter of an affiliated corporation that does calculate and report an individual corporate excise pursuant to such combined report.",
          "role": "corporate_return_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/44f8cf37b309037b5d037d5575d8c66edebadcd1713a91af856b21605a3d5d53.html",
          "source_sha256": "44f8cf37b309037b5d037d5575d8c66edebadcd1713a91af856b21605a3d5d53",
          "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter62C/Section11"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The corporation applies to the commissioner for security-corporation classification before the taxable year ends; the general Chapter 62C corporate-return rule also applies.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 38B(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Every financial institution or business corporation which is engaged exclusively in buying, selling, dealing in, or holding securities on its own behalf and not as a broker, except securities of a DISC, and is not a bank holding company under the Internal Revenue Code, as amended and in effect for the taxable year, and, which either applies to the commissioner to be classified as a security corporation before the end of the taxable year and is so classified, or has been so classified by the commissioner for a prior taxable year and such classification has not been revoked before the end of the taxable year, shall pay, on account of each taxable year, an excise equal to one and thirty-two one hundredths percent of the gross income, as defined in section thirty, received by such corporation during the taxable year or four hundred and fifty-six dollars, whichever is greater.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.tax_regime.corporate_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Section 39 imposes the corporate excise on every covered business corporation for stated charter, business, and property incidents in Massachusetts.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 39",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Section 39. Except as otherwise provided in this section, every business corporation, organized under the laws of the commonwealth, or exercising its charter or other means of legal authority, or qualified to do business or actually doing business in the commonwealth, or owning or using any part or all of its capital, plant or any other property in the commonwealth, shall pay, on account of each taxable year, the excise provided in subsection (a) or (b), whichever is greater, except that an insurance mutual holding company established under chapter 175 or under the equivalent law of another state shall pay, on account of each taxable year, only the excise provided in clause (2) of subsection (a) or subsection (b), whichever is greater. Without limitation, the excise levied in this section is due and payable on any 1 or all of the following alternative incidents:— (1) The authority or qualification to carry on or do business in this state or the actual doing of business within the commonwealth. The term ''doing business'' as used herein shall mean and include each and every act, power, right, privilege, or immunity exercised or enjoyed in the commonwealth, as an incident to or by virtue of the powers and privileges acquired by the nature of those organizations, as well as, the buying, selling or procuring of services or property. (2) The exercising or continuance of a business corporation's charter or other means of legal authority within the commonwealth. (3) The owning or using any part or all of its capital, plant or other property in the commonwealth. It is the purpose of this section to require the payment of this excise to the commonwealth by a business corporation for the enjoyment under the protection of the laws of the commonwealth, of the powers, rights, privileges and immunities derived by reason of its existence and operation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/d8070a087898fa5615bf4811e59d1dfb9cb3dd65459dd5ef55e45ad0c73ca851.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d8070a087898fa5615bf4811e59d1dfb9cb3dd65459dd5ef55e45ad0c73ca851",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section39",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.tax_regime.elective_pass_through_entity_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "An eligible pass-through entity may elect the Chapter 63D excise on qualified income taxable in Massachusetts.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63D, § 2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Section 2. An eligible pass-through entity may elect to pay an excise on its qualified income taxable in Massachusetts at a rate of 5 per cent. A qualified member of an electing eligible pass-through entity shall be allowed a refundable credit against the tax imposed under this chapter. The credit shall be available to qualified members in an amount proportionate to each qualified member's share of the tax due and paid under this chapter by the eligible pass-through entity multiplied by 0.9. The credit shall be available for the member's taxable year in which the electing eligible pass-through entity's taxable year ends.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/33e72a50e664d1cbf923d42a57b096dd98732b38a1180e154cca9d595d538b84.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33e72a50e664d1cbf923d42a57b096dd98732b38a1180e154cca9d595d538b84",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section2",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.tax_regime.security_corporation_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Section 38B imposes a gross-income-measured excise on a qualifying financial institution or business corporation classified as a security corporation.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 38B(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Every financial institution or business corporation which is engaged exclusively in buying, selling, dealing in, or holding securities on its own behalf and not as a broker, except securities of a DISC, and is not a bank holding company under the Internal Revenue Code, as amended and in effect for the taxable year, and, which either applies to the commissioner to be classified as a security corporation before the end of the taxable year and is so classified, or has been so classified by the commissioner for a prior taxable year and such classification has not been revoked before the end of the taxable year, shall pay, on account of each taxable year, an excise equal to one and thirty-two one hundredths percent of the gross income, as defined in section thirty, received by such corporation during the taxable year or four hundred and fifty-six dollars, whichever is greater.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.treatment.corporate_excise": {
      "additional_sources": [
        {
          "pinpoint": "M.G.L. c. 63, § 38B(a)",
          "quote": "(a) Every financial institution or business corporation which is engaged exclusively in buying, selling, dealing in, or holding securities on its own behalf and not as a broker, except securities of a DISC, and is not a bank holding company under the Internal Revenue Code, as amended and in effect for the taxable year, and, which either applies to the commissioner to be classified as a security corporation before the end of the taxable year and is so classified, or has been so classified by the commissioner for a prior taxable year and such classification has not been revoked before the end of the taxable year, shall pay, on account of each taxable year, an excise equal to one and thirty-two one hundredths percent of the gross income, as defined in section thirty, received by such corporation during the taxable year or four hundred and fifty-six dollars, whichever is greater.",
          "role": "alternate_security_excise",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
          "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
          "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 38B(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Any corporation taxable under this section shall not be subject to the excise imposed by section 2, 2B, 32D or 39.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.treatment.elective_pass_through_entity_excise": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "Chapter 63D states the elective qualified-income rule but no distinct treatment for a holding or passive eligible pass-through entity.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/33e72a50e664d1cbf923d42a57b096dd98732b38a1180e154cca9d595d538b84.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33e72a50e664d1cbf923d42a57b096dd98732b38a1180e154cca9d595d538b84",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section2",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MA.llc.treatment.security_corporation_excise": {
      "additional_sources": [
        {
          "pinpoint": "M.G.L. c. 63, § 38B(a)",
          "quote": "(a) Every financial institution or business corporation which is engaged exclusively in buying, selling, dealing in, or holding securities on its own behalf and not as a broker, except securities of a DISC, and is not a bank holding company under the Internal Revenue Code, as amended and in effect for the taxable year, and, which either applies to the commissioner to be classified as a security corporation before the end of the taxable year and is so classified, or has been so classified by the commissioner for a prior taxable year and such classification has not been revoked before the end of the taxable year, shall pay, on account of each taxable year, an excise equal to one and thirty-two one hundredths percent of the gross income, as defined in section thirty, received by such corporation during the taxable year or four hundred and fifty-six dollars, whichever is greater.",
          "role": "security_excise_imposition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
          "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
          "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A qualifying security corporation is outside the general § 39 excise and pays the separate gross-income-measured § 38B excise.",
      "fetch_event_id": null,
      "pinpoint": "M.G.L. c. 63, § 38B(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Any corporation taxable under this section shall not be subject to the excise imposed by section 2, 2B, 32D or 39.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MA/snapshots/c50/MA/2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2736f6125182e209a89f93b6994f94f4b5616df8389da402875806e8be1cb313",
      "source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Md. Code, Tax–General § 10-304(1)",
          "quote": "Except as provided in Subtitle 4 of this title, the Maryland modified income of a corporation, including a real estate investment trust or regulated investment company, is: (1) the corporation’s federal taxable income for the taxable year as determined under the Internal Revenue Code and as adjusted under this Part II of this subtitle;",
          "role": "corporate base",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate rate is located at § 10-105(b), and the corporate Maryland modified-income base is located at § 10-304.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-105(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The State income tax rate for a corporation is 8.25% of Maryland taxable",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.base_tax_locator.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The PTE rate formulas and taxable-income or nonresident-taxable-income bases are located at § 10-102.1(d).",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-102.1(d)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to a pass–through entity that pays the tax imposed under subsection (b)(1) of this section in accordance with subsection (b)(2)(i) of this section, the tax imposed is the sum of:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Md. Code, Tax–General § 10-307(a)",
          "quote": "To the extent included in federal taxable income, the amounts under this section are subtracted from the federal taxable income of a corporation to determine Maryland modified income.",
          "role": "federal-income inclusion condition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The subtraction is limited to included dividends, at least 50% direct or indirect ownership, and a payer organized under foreign law.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-307(d)(1)-(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "the receiving corporation owns, directly or indirectly, 50% or more of the paying corporation’s outstanding shares of capital stock; and (2) the paying corporation is organized under the laws of a foreign government.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.does_not_reach.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Md. Code, Tax–General § 10-102.1(f)(2)(i)",
          "quote": "under subsection (b)(2)(ii) of this section does not apply with respect to the direct or indirect distributive share or pro rata share of a member that is: (i) a real estate investment trust as defined by § 856 of the Internal Revenue Code; or",
          "role": "REIT-member limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
        },
        {
          "pinpoint": "Md. Code, Tax–General § 10-102.1(f)(2)(ii)",
          "quote": "an entity that is exempt from taxation under § 501 of the",
          "role": "tax-exempt-member limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The non-elective tax excludes specified shares of Maryland PTE, REIT, and Internal Revenue Code § 501 members.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-102.1(f)(1)(i)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax imposed under subsection (b)(1) of this section that is paid in accordance with subsection (b)(2)(i) of this section and for which no election is made under subsection (b)(2)(ii) of this section does not apply with respect to the distributive share or pro rata share of a member that is itself a pass–through entity formed under the laws of the State or qualified by or registered with the Department of Assessments and Taxation to do business in the State.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current corporate levy and dividend-subtraction provisions do not state an effective or sunset period in the codified sections.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General §§ 10-102, 10-105(b), 10-304, and 10-307; complete search",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.effective_period.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Md. Code, Tax–General § 10-819.1(b)",
          "quote": "For a taxable year beginning after December 31, 2026, a pass–through entity shall file an income tax return electronically.",
          "role": "filing-mode date",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current PTE levy provision does not state an effective or sunset period; § 10-819.1 separately dates the future electronic-filing rule.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General §§ 10-102.1, 10-819, and 10-819.1; complete search",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "An LLC classified under federal Subchapter C or S files the appropriate corporate return; a disregarded single-member LLC reports through its member.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-819",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each limited liability company as defined under Title 4A of the Corporations and Associations Article shall file an income tax return unless it has only one member and it is disregarded as an entity separate from its member for federal income tax purposes. (b) (1) If the limited liability company is classified as a partnership, as defined in § 761 of the Internal Revenue Code, it shall file a partnership tax return. (2) If the limited liability company is classified as a corporation under Chapter 1, Subchapter C or Subchapter S of the Internal Revenue Code, it shall file the appropriate corporate tax return. (c) If the limited liability company has only one member and it is disregarded as an entity separate from its member for federal income tax purposes, the profit or loss of the limited liability company shall be reflected on the income tax return filed by the member of the limited liability company.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.filing_rule.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Md. Code, Tax–General § 10-819.1(b)",
          "quote": "For a taxable year beginning after December 31, 2026, a pass–through entity shall file an income tax return electronically.",
          "role": "future electronic-filing rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-819",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each limited liability company as defined under Title 4A of the Corporations and Associations Article shall file an income tax return unless it has only one member and it is disregarded as an entity separate from its member for federal income tax purposes. (b) (1) If the limited liability company is classified as a partnership, as defined in § 761 of the Internal Revenue Code, it shall file a partnership tax return. (2) If the limited liability company is classified as a corporation under Chapter 1, Subchapter C or Subchapter S of the Internal Revenue Code, it shall file the appropriate corporate tax return. (c) If the limited liability company has only one member and it is disregarded as an entity separate from its member for federal income tax purposes, the profit or loss of the limited liability company shall be reflected on the income tax return filed by the member of the limited liability company.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MD.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Maryland imposes income tax on the Maryland taxable income of each corporation, subject to the statutory exclusions.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-102",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as provided in § 10-104 of this subtitle, a tax is imposed on the Maryland taxable income of each individual and of each corporation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MD.llc.tax_regime.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Each pass-through entity must pay the tax for nonresident-member shares or may elect to pay it for all member shares.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-102.1(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subject to paragraph (2) of this subsection, in addition to any other tax imposed under this title, a tax is imposed on each pass–through entity. (2) Each pass–through entity: (i) shall pay the tax imposed under paragraph (1) of this subsection with respect to the distributive shares or pro rata shares of the nonresident and nonresident entity members of the pass–through entity; or (ii) may elect to pay the tax imposed under paragraph (1) of this subsection with respect to the distributive shares or pro rata shares of all members of the pass–through entity.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MD.llc.treatment.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Md. Code, Tax–General § 10-307(d)",
          "quote": "The subtraction under subsection (a) of this section includes dividends received from a corporation if:",
          "role": "dividend subtraction",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
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        {
          "pinpoint": "Md. Code, Tax–General § 10-307(d)(1)-(2)",
          "quote": "the receiving corporation owns, directly or indirectly, 50% or more of the paying corporation’s outstanding shares of capital stock; and (2) the paying corporation is organized under the laws of a foreign government.",
          "role": "ownership and payer conditions",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Qualifying foreign-corporation dividends are subtracted from federal taxable income when determining Maryland modified income.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-307(a)",
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      "publish_status": "publish_ready",
      "quote": "To the extent included in federal taxable income, the amounts under this section are subtracted from the federal taxable income of a corporation to determine Maryland modified income.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MD.llc.treatment.pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Md. Code, Tax–General § 10-102.1(a)(7)",
          "quote": "“Pass–through entity” means: (i) an S corporation; (ii) a partnership; (iii) a limited liability company that is not taxed as a corporation under this title; or (iv) a business trust or statutory trust that is not taxed as a corporation under this title.",
          "role": "covered LLC",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
          "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
          "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Md. Code, Tax–General § 10-102.1(b)",
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      "publish_status": "publish_ready",
      "quote": "Subject to paragraph (2) of this subsection, in addition to any other tax imposed under this title, a tax is imposed on each pass–through entity. (2) Each pass–through entity: (i) shall pay the tax imposed under paragraph (1) of this subsection with respect to the distributive shares or pro rata shares of the nonresident and nonresident entity members of the pass–through entity; or (ii) may elect to pay the tax imposed under paragraph (1) of this subsection with respect to the distributive shares or pro rata shares of all members of the pass–through entity.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MD/snapshots/c50/MD/b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b6b7c22997ee4d97b8e4d574cc1e9cd68e4d633395376ecd7b776ee686fc581d",
      "source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#ME.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Rates and imposition: § 5200(1-A); Maine taxable-income modifications: § 5200-A.",
      "fetch_event_id": null,
      "pinpoint": "Me. Rev. Stat. tit. 36, § 5200(1-A)",
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      "quote": "For tax years beginning on or after January 1, 2018, a tax is imposed for each taxable year at the following rates on each taxable corporation and on each group of corporations that derives income from a unitary business carried on by 2 or more members of an affiliated group: If the income is: The tax is: Not over $350,000 3.5% of the income $350,000 but not over $1,050,000 $12,250 plus 7.93% of the excess over $350,000 $1,050,000 but not over $3,500,000 $67,760 plus 8.33% of the excess over $1,050,000 $3,500,000 or more $271,845 plus 8.93% of the excess over $3,500,000 In the case of an affiliated group of corporations engaged in a unitary business with activity taxable only by Maine, the rates provided in this subsection are applied only to the first $3,500,000 of the Maine net income of the entire group and must be apportioned equally among the taxable corporations unless those taxable corporations jointly elect a different apportionment. The balance of the Maine net income of the entire group is taxed at 8.93%. In the case of an affiliated group of corporations engaged in a unitary business with activity taxable both within and without this State, the rates provided in this subsection are applied only to the first $3,500,000 of the net income of the entire group and must be apportioned equally among the taxable corporations unless those taxable corporations jointly elect a different apportionment. The balance of the net income of the entire group is taxed at 8.93%. [PL 2017, c. 474, Pt. E, §2 (NEW).]",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ME/snapshots/c50/ME/sec5200.html/442cf5e27a865a870618e68760255afd44a7ec4eff4d4771ab74d4a3a44dcf17.html",
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    "holding_tax:pp-holding-entity-tax#ME.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": [
        {
          "evidence_role": "scope_limitation",
          "pinpoint": "Me. Rev. Stat. tit. 36, § 5200-B(4)",
          "quote": "Federal protection. A state that is without jurisdiction to impose a tax on the net income of a taxpayer because that taxpayer comes under the protection of 15 United States Code, Sections 381 to 384, does not gain jurisdiction to impose such a tax because the taxpayer's property, payroll or sales in the State exceed a threshold established in subsection 1 . [PL 2021, c. 181, Pt. E, §2 (NEW); PL 2021, c. 181, Pt. E, §4 (AFF).]",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/ME/snapshots/c50/ME/sec5200-B.html/ME/99cfde40865933813eeb4591b28b4e09dd7c72e4bf3e874d58331a4d64476680.html",
          "source_sha256": "99cfde40865933813eeb4591b28b4e09dd7c72e4bf3e874d58331a4d64476680",
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      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The dividend subtraction excludes subpart F, § 951A and § 965 income; § 5200-B also preserves federal Public Law 86-272 protection.",
      "fetch_event_id": null,
      "pinpoint": "Me. Rev. Stat. tit. 36, § 5200-A(2)(G)",
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      "quote": "Fifty percent of the apportionable dividend income, net of related expenses and other related deductions deducted in computing federal taxable income, the taxpayer received during the taxable year from an affiliated corporation that is not included with the taxpayer in a Maine combined report. Dividend income does not include subpart F income, as defined in the Code, Section 952, income included in federal taxable income in accordance with the Code, Section 951A or income included in federal taxable income in accordance with the Code, Section 965. Any amount subtracted from federal taxable income under this paragraph must be excluded from the sales factor of any apportionment formula employed to attribute income to this State; [PL 2017, c. 474, Pt. D, §2 (AMD); PL 2017, c. 474, Pt. D, §4 (AFF).]",
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      "additional_sources": null,
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      "claim_type": "operative_rule",
      "display": "The current rate schedule applies to tax years beginning on or after January 1, 2018.",
      "fetch_event_id": null,
      "pinpoint": "Me. Rev. Stat. tit. 36, § 5200(1-A)",
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      "quote": "For tax years beginning on or after January 1, 2018, a tax is imposed for each taxable year at the following rates on each taxable corporation and on each group of corporations that derives income from a unitary business carried on by 2 or more members of an affiliated group:",
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      "source_sha256": "442cf5e27a865a870618e68760255afd44a7ec4eff4d4771ab74d4a3a44dcf17",
      "source_url": "https://legislature.maine.gov/statutes/36/title36sec5200.html",
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    "holding_tax:pp-holding-entity-tax#ME.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Every taxable corporation required to file a federal income-tax return files a Maine return; a unitary affiliate also files the statutory combined report.",
      "fetch_event_id": null,
      "pinpoint": "Me. Rev. Stat. tit. 36, § 5220(5)",
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      "publish_status": "publish_ready",
      "quote": "Certain taxable corporations. Every taxable corporation that is required to file a federal income tax return. A taxable corporation that is a member of an affiliated group and that is engaged in a unitary business with one or more other members of that affiliated group shall file, in addition, a combined report, in accordance with section 5244 . The State Tax Assessor may allow 2 or more taxable corporations that are members of an affiliated group and that are engaged in a unitary business to file a single return on which the aggregate Maine income tax liability of all those corporations is reported. [PL 1997, c. 404, §6 (AMD); PL 1997, c. 404, §10 (AFF).]",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ME/snapshots/c50/ME/sec5220.html/ME/c2c7387c64a7a6c573c7cd67b86eaf51839bd920a436ae12427bb4df6ef8b7f2.html",
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      "source_url": "https://legislature.maine.gov/statutes/36/title36sec5220.html",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "For tax years beginning on or after January 1, 2018, § 5200 imposes tax on each taxable corporation and each qualifying unitary group.",
      "fetch_event_id": null,
      "pinpoint": "Me. Rev. Stat. tit. 36, § 5200(1-A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For tax years beginning on or after January 1, 2018, a tax is imposed for each taxable year at the following rates on each taxable corporation and on each group of corporations that derives income from a unitary business carried on by 2 or more members of an affiliated group: If the income is: The tax is: Not over $350,000 3.5% of the income $350,000 but not over $1,050,000 $12,250 plus 7.93% of the excess over $350,000 $1,050,000 but not over $3,500,000 $67,760 plus 8.33% of the excess over $1,050,000 $3,500,000 or more $271,845 plus 8.93% of the excess over $3,500,000 In the case of an affiliated group of corporations engaged in a unitary business with activity taxable only by Maine, the rates provided in this subsection are applied only to the first $3,500,000 of the Maine net income of the entire group and must be apportioned equally among the taxable corporations unless those taxable corporations jointly elect a different apportionment. The balance of the Maine net income of the entire group is taxed at 8.93%. In the case of an affiliated group of corporations engaged in a unitary business with activity taxable both within and without this State, the rates provided in this subsection are applied only to the first $3,500,000 of the net income of the entire group and must be apportioned equally among the taxable corporations unless those taxable corporations jointly elect a different apportionment. The balance of the net income of the entire group is taxed at 8.93%. [PL 2017, c. 474, Pt. E, §2 (NEW).]",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ME/snapshots/c50/ME/sec5200.html/442cf5e27a865a870618e68760255afd44a7ec4eff4d4771ab74d4a3a44dcf17.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "442cf5e27a865a870618e68760255afd44a7ec4eff4d4771ab74d4a3a44dcf17",
      "source_url": "https://legislature.maine.gov/statutes/36/title36sec5200.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#ME.llc.treatment.corporate_income_tax": {
      "additional_sources": [
        {
          "evidence_role": "income_modification",
          "pinpoint": "Me. Rev. Stat. tit. 36, § 5200-A(2)(G)",
          "quote": "Fifty percent of the apportionable dividend income, net of related expenses and other related deductions deducted in computing federal taxable income, the taxpayer received during the taxable year from an affiliated corporation that is not included with the taxpayer in a Maine combined report. Dividend income does not include subpart F income, as defined in the Code, Section 952, income included in federal taxable income in accordance with the Code, Section 951A or income included in federal taxable income in accordance with the Code, Section 965. Any amount subtracted from federal taxable income under this paragraph must be excluded from the sales factor of any apportionment formula employed to attribute income to this State; [PL 2017, c. 474, Pt. D, §2 (AMD); PL 2017, c. 474, Pt. D, §4 (AFF).]",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/ME/snapshots/c50/ME/sec5200-A.html/d32bf96573dc0638087787d759a1db4dea21879707a1a8911f8927a094ddebca.html",
          "source_sha256": "d32bf96573dc0638087787d759a1db4dea21879707a1a8911f8927a094ddebca",
          "source_url": "https://legislature.maine.gov/statutes/36/title36sec5200-A.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A corporate SBIC meeting § 5202-A is exempt under Part 8; § 5200-A separately subtracts 50% of specified affiliated-corporation dividend income.",
      "fetch_event_id": null,
      "pinpoint": "Me. Rev. Stat. tit. 36, § 5202-A",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Corporate small business investment companies, licensed under the United States Small Business Investment Act of 1958, as amended, and commercially domiciled in Maine and doing business primarily in Maine, shall be exempt from taxation under this Part. [PL 1977, c. 640, §2 (NEW).]",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ME/snapshots/c50/ME/sec5202-A.html/ME/9658f4f9832d1206a48f45ebc99c7b232eae7a1f350d158b4b7f455ba9e18006.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9658f4f9832d1206a48f45ebc99c7b232eae7a1f350d158b4b7f455ba9e18006",
      "source_url": "https://legislature.maine.gov/statutes/36/title36sec5202-A.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The Corporate Income Tax base and holding-income adjustments are located in MCL 206.623; MCL 206.667 addresses alternative apportionment.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.623(1)-(4)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as otherwise provided in this part, there is levied and imposed a corporate income tax on every taxpayer with business activity within this state or ownership interest or beneficial interest in a flow-through entity that has business activity in this state unless prohibited by 15 USC 381 to 384. The corporate income tax is imposed on the corporate income tax base, after allocation or apportionment to this state, at the rate of 6.0%.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.base_tax_locator.flow_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The FTE tax base, adjustments and member-allocation rule are located in MCL 206.815; MCL 206.817 governs apportionment.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.815(1)-(5)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subject to section 847, beginning January 1, 2021 and each tax year after 2021, there is levied and imposed a flow-through entity tax on every taxpayer with business activity in this state unless prohibited by 15 USC 381 to 384. Except as otherwise provided under subsection (5), the flow-through entity tax is imposed on the positive business income tax base, after allocation or apportionment to this state, at the same rate levied and imposed under section 51 for that same tax year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The quoted deductions are bounded by their stated sources: specified non-U.S. payors/foreign operating entities and United States obligations.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.623(2)(d), (f)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "To the extent included in federal taxable income, deduct dividends and royalties received from persons other than United States persons and foreign operating entities, including, but not limited to, amounts determined under section 78 of the internal revenue code or sections 951 to 965 of the internal revenue code. […] To the extent included in federal taxable income, deduct interest income derived from United States obligations.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.does_not_reach.flow_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.815(3)-(4)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) For a taxpayer that has a direct, or indirect through 1 or more other flow-through entities, ownership or beneficial interest in a flow-through entity for which an election was made under section 813 and that reported positive business income in a tax year ending on or within the taxpayer's tax year, the adjustments in subsection (2) shall not include the taxpayer's share of the electing flow-through entities adjustments under subsection (2). (4) For a taxpayer that has a direct, or indirect through 1 or more other flow-through entities, ownership or beneficial interest in a flow-through entity for which an election was not made under section 813, add the taxpayer's share of the non-electing flow-through entity's positive business income as determined under section 817(2).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The Corporate Income Tax part was added by 2011 PA 38, effective January 1, 2012.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.623, History",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Add. 2011, Act 38, Eff. Jan. 1, 2012",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.effective_period.flow_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.813; MCL 206.847",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For tax years beginning on and after January 1, 2021, a flow-through entity may, in a form and manner as prescribed by the department, elect to file a return and pay the tax imposed by this part. […] The tax created under this part is levied and imposed for any tax year that section 164(b)(6)(B) of the internal revenue code limits the amount an individual is allowed to deduct under section 164(a) of the internal revenue code for the same tax year. The tax created under this part is not levied and imposed for any tax year that section 164(b)(6)(B) of the internal revenue code does not limit the amount an individual is allowed to deduct under section 164(a) of the internal revenue code for the same tax year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The annual or final corporate-income-tax return is due by the last day of the fourth month after the tax year ends.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.685(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An annual or final return shall be filed with the department in the form and content prescribed by the department by the last day of the fourth month after the end of the taxpayer's tax year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.filing_rule.flow_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "An annual or final FTE return is due by the last day of the third month after the taxpayer's tax year ends.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.833(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An annual or final return for the tax imposed under this part shall be filed with the department in the form and content prescribed by the department by the last day of the third month after the end of the taxpayer's tax year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.623(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as otherwise provided in this part, there is levied and imposed a corporate income tax on every taxpayer with business activity within this state or ownership interest or beneficial interest in a flow-through entity that has business activity in this state unless prohibited by 15 USC 381 to 384. The corporate income tax is imposed on the corporate income tax base, after allocation or apportionment to this state, at the rate of 6.0%.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.tax_regime.flow_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Subject to MCL 206.847, Michigan levies Flow-Through Entity Tax on every electing taxpayer with Michigan business activity.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.815(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subject to section 847, beginning January 1, 2021 and each tax year after 2021, there is levied and imposed a flow-through entity tax on every taxpayer with business activity in this state unless prohibited by 15 USC 381 to 384. Except as otherwise provided under subsection (5), the flow-through entity tax is imposed on the positive business income tax base, after allocation or apportionment to this state, at the same rate levied and imposed under section 51 for that same tax year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A corporate-classified holding LLC receives different base treatment for the specified foreign dividends/royalties and U.S.-obligation interest.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.623(2)(d), (f)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "To the extent included in federal taxable income, deduct dividends and royalties received from persons other than United States persons and foreign operating entities, including, but not limited to, amounts determined under section 78 of the internal revenue code or sections 951 to 965 of the internal revenue code. […] To the extent included in federal taxable income, deduct interest income derived from United States obligations.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MI.llc.treatment.flow_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "MCL 206.815(2)(h), (3)-(4)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Deduct business income received as a member of another flow-through entity to the extent that the business income increased federal taxable income. […] (3) For a taxpayer that has a direct, or indirect through 1 or more other flow-through entities, ownership or beneficial interest in a flow-through entity for which an election was made under section 813 and that reported positive business income in a tax year ending on or within the taxpayer's tax year, the adjustments in subsection (2) shall not include the taxpayer's share of the electing flow-through entities adjustments under subsection (2). (4) For a taxpayer that has a direct, or indirect through 1 or more other flow-through entities, ownership or beneficial interest in a flow-through entity for which an election was not made under section 813, add the taxpayer's share of the non-electing flow-through entity's positive business income as determined under section 817(2).",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/structuring/discovery/MI/snapshots/c50/act-281-full/MI/33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "33716349d3de3e783375caa5f8a044a925b426dddab4b4a4bf7b99cce6f2d4f4",
      "source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.base_tax_locator.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.0921, subd. 1",
          "quote": "Subdivision 1. Tax imposed. In addition to the taxes computed under this chapter without regard to this section, the franchise tax imposed on corporations includes a tax equal to the excess, if any, for the taxable year of:",
          "role": "corporate AMT component",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The franchise-tax measures and rate are located in §§290.02 and 290.06, subd. 1; §290.0921 supplies the included AMT component. No amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.02",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax so imposed is measured by the corporations' taxable income and alternative minimum taxable income for the taxable year for which the tax is imposed, and computed in the manner and at the rates provided in this chapter.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The qualifying-owner liability sum, income base, and individual-rate cross-reference are located in §289A.08, subd. 7a(c)-(d); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.08, subd. 7a(d)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(d) The amount of a qualifying owner's tax liability under paragraph (c) is the amount of the qualifying owner's income multiplied by the highest tax rate for individuals under section 290.06, subdivision 2c. The computation of a qualifying owner's net investment income tax liability must be computed under section 290.033.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.base_tax_locator.minimum_fee": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.0922, subd. 3(b)",
          "quote": "(b) \"Minnesota property\" means total Minnesota tangible property as provided in section 290.191, subdivisions 9 to 11, any other tangible property located in Minnesota, but does not include the property of a qualified business as defined under section 469.310, subdivision 11, that is located in a job opportunity building zone designated under section 469.314. Intangible property shall not be included in Minnesota property for purposes of this section.",
          "role": "property-factor definition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The filing-entity imposition, factor thresholds, and factor definitions are located in §290.0922, subds. 1 and 3; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.0922, subd. 1(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) A tax is imposed for each taxable year on a corporation required to file a return under section 289A.12, subdivision 3, that is treated as an S corporation under section 290.9725 and on a partnership required to file a return under section 289A.12, subdivision 3, other than a partnership that derives over 80 percent of its income from farming.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.base_tax_locator.s_corporation_built_in_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The imposition, lesser-of taxable-net-income computation, loss carryforward, and rate locator are in §290.9727, subds. 1-4; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9727, subd. 3",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subd. 3. Taxable net income. For purposes of this section, taxable net income means the lesser of: (1) the recognized built-in gains of the S corporation for the taxable year, as determined under section 1374 of the Internal Revenue Code, subject to the modifications provided in section 290.0135, that are allocable to this state under section 290.17, 290.191, or 290.20; or",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.base_tax_locator.s_corporation_capital_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The imposition, corporate-rate reference, and lesser-of capital-gain income base are located in §290.9728, subds. 1-2; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9728, subd. 2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subd. 2. Taxable income. For purposes of this section, taxable income means the lesser of: (1) the amount of the net capital gain of the S corporation for the taxable year, as determined under sections 1222 and 1374 of the Internal Revenue Code, and subject to the modifications provided in section 290.0135, in excess of $25,000 that is allocable to this state under section 290.17, 290.191, or 290.20; or",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.base_tax_locator.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The imposition, corporate-rate reference, and lesser-of excess-net-passive-income base are in §290.9729, subds. 1-2; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9729, subd. 2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subd. 2. Taxable income. For the purposes of this section, taxable income means the lesser of: (1) the amount of the S corporation's excess net passive income, as determined under section 1375 of the Internal Revenue Code, subject to the provisions of sections 290.0133 to 290.0135, that is allocable to this state under section 290.17, 290.191, or 290.20; or",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.does_not_reach.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.21, subd. 4(c)",
          "quote": "The dividend deduction provided in this subdivision does not apply to a dividend received from a real estate investment trust as defined in section 856 of the Internal Revenue Code.",
          "role": "REIT-dividend exclusion",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The dividend deduction does not reach dividends from a federally exempt corporation or a REIT and is subject to the holding-business exclusion.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.21, subd. 4(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The dividend deduction provided in this subdivision does not apply to a dividend from a corporation which, for the taxable year of the corporation in which the distribution is made or for the next preceding taxable year of the corporation, is a corporation exempt from tax under section 501 of the Internal Revenue Code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §289A.08, subd. 7a(b)(2)",
          "quote": "(b) For taxable years beginning after December 31, 2020, a qualifying entity may elect to file a return and pay the pass-through entity tax imposed under paragraph (c). The election: (1) must be made on or before the due date or extended due date of the qualifying entity's pass-through entity tax return; (2) must exclude partners, members, shareholders, or owners who are not qualifying owners; (3) may only be made by qualifying owners who collectively hold more than 50 percent of the ownership interests in the qualifying entity held by qualifying owners; (4) is binding on all qualifying owners who have an ownership interest in the qualifying entity; and (5) once made is irrevocable for the taxable year.",
          "role": "nonqualifying-owner exclusion",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
          "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "A publicly traded partnership is not a qualifying entity, and the election must exclude owners who are not qualifying owners.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.08, subd. 7a(a)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Qualifying entity does not include a publicly traded partnership, as defined in section 7704 of the Internal Revenue Code;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.does_not_reach.minimum_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The fee does not reach the expressly exempt entities, including REITs, regulated investment companies or their funds, and §860D(b)-electing entities.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.0922, subd. 2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subd. 2. Exemptions. The following entities are exempt from the tax imposed by this section: (1) corporations exempt from tax under section 290.05; (2) real estate investment trusts; (3) regulated investment companies or a fund thereof; (4) entities having a valid election in effect under section 860D(b) of the Internal Revenue Code; (5) township mutual insurance companies; (6) cooperatives organized under chapter 308A, 308B, or 308C that provide housing exclusively to persons age 55 and over and are classified as homesteads under section 273.124, subdivision 3; and (7) a qualified business as defined under section 469.310, subdivision 11, if for the taxable year all of its property is located in a job opportunity building zone designated under section 469.314 and all of its payroll is a job opportunity building zone payroll under section 469.310.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.does_not_reach.s_corporation_built_in_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The subdivision does not apply when the corporation had an S election in effect for every taxable year; predecessor status is combined.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9727, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "This subdivision does not apply to any corporation having an S election in effect for each of its taxable years. An S corporation and any predecessor corporation must be treated as one corporation for purposes of the preceding sentence.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.does_not_reach.s_corporation_capital_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9728, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "This section does not apply to an S corporation which has had an election under section 1362 of the Internal Revenue Code of 1954, in effect for the three immediately preceding taxable years. This section does not apply to an S corporation that has been in existence for less than four taxable years and has had an election in effect under section 1362 of the Internal Revenue Code of 1954 for each of the corporation's taxable years.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.does_not_reach.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The Minnesota tax is waived when the taxpayer receives the corresponding federal §1375(d) waiver.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9729, subd. 3",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subd. 3. Waiver of tax. The tax imposed by this section shall be waived if the taxpayer receives a waiver for federal income tax purposes under section 1375(d) of the Internal Revenue Code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.effective_period.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No current sunset or effective period for the franchise-tax regime was stated in the complete chapter 290 capture.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §289A.08, subd. 7a(l)",
          "quote": "(l) This subdivision expires at the same time and on the same terms as section 164(b)(6)(B) of the Internal Revenue Code, except that the expiration of this subdivision does not affect the commissioner's authority to audit or power of examination and assessments for credits claimed under this section.",
          "role": "expiration term",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
          "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The election applies to taxable years beginning after 2020 and expires with federal IRC §164(b)(6)(B), without ending later audit authority.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.08, subd. 7a(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) For taxable years beginning after December 31, 2020, a qualifying entity may elect to file a return and pay the pass-through entity tax imposed under paragraph (c). The election: (1) must be made on or before the due date or extended due date of the qualifying entity's pass-through entity tax return; (2) must exclude partners, members, shareholders, or owners who are not qualifying owners; (3) may only be made by qualifying owners who collectively hold more than 50 percent of the ownership interests in the qualifying entity held by qualifying owners; (4) is binding on all qualifying owners who have an ownership interest in the qualifying entity; and (5) once made is irrevocable for the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.effective_period.minimum_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No current sunset or effective period for the minimum fee was stated in the complete chapter 290 capture.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.effective_period.s_corporation_built_in_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The stated S-election condition is an election after December 31, 1986.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9727, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subdivision 1. Tax imposed. For an S corporation electing S corporation status pursuant to section 1362 of the Internal Revenue Code after December 31, 1986, and having a recognized built-in gain as defined in section 1374 of the Internal Revenue Code, there is imposed a tax on the taxable income of such S corporation, as defined in this section, at the rate prescribed by section 290.06, subdivision 1.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.effective_period.s_corporation_capital_gains_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.9728, subd. 1",
          "quote": "This section does not apply to an S corporation which has had an election under section 1362 of the Internal Revenue Code of 1954, in effect for the three immediately preceding taxable years. This section does not apply to an S corporation that has been in existence for less than four taxable years and has had an election in effect under section 1362 of the Internal Revenue Code of 1954 for each of the corporation's taxable years.",
          "role": "lookback exclusions",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Eligibility is limited to an S corporation whose federal S election was made before January 1, 1987, subject to the stated lookback exclusions.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9728, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subdivision 1. Tax imposed. There is imposed a tax on the taxable income of an S corporation that has: (1) elected S corporation status pursuant to section 1362 of the Internal Revenue Code of 1986, as amended through December 31, 1986, before January 1, 1987; (2) a net capital gain for the taxable year (i) in excess of $25,000 and (ii) exceeding 50 percent of the corporation's federal taxable income for the taxable year; and (3) federal taxable income for the taxable year exceeding $25,000.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.effective_period.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No current sunset or effective period for the S-corporation passive-investment-income tax was stated in the complete chapter 290 capture.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.filing_rule.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "A corporation within Minnesota's jurisdiction to tax must file a return.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.08, subd. 3(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subd. 3. Corporations. (a) A corporation that is subject to the state's jurisdiction to tax under section 290.014, subdivision 5, must file a return.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.08, subd. 7a(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) For taxable years beginning after December 31, 2020, a qualifying entity may elect to file a return and pay the pass-through entity tax imposed under paragraph (c). The election: (1) must be made on or before the due date or extended due date of the qualifying entity's pass-through entity tax return; (2) must exclude partners, members, shareholders, or owners who are not qualifying owners; (3) may only be made by qualifying owners who collectively hold more than 50 percent of the ownership interests in the qualifying entity held by qualifying owners; (4) is binding on all qualifying owners who have an ownership interest in the qualifying entity; and (5) once made is irrevocable for the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.filing_rule.minimum_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.0922, subd. 1(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) A tax is imposed for each taxable year on a corporation required to file a return under section 289A.12, subdivision 3, that is treated as an S corporation under section 290.9725 and on a partnership required to file a return under section 289A.12, subdivision 3, other than a partnership that derives over 80 percent of its income from farming.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.filing_rule.s_corporation_built_in_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "An S corporation files a return for each taxable year in which its federal S election is in effect.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.12, subd. 3(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) An S corporation must file a return with the commissioner for a taxable year during which an election under section 290.9725 is in effect, stating specifically the names and addresses of the persons owning stock in the corporation at any time during the taxable year, the number of shares of stock owned by a shareholder at all times during the taxable year, the shareholder's pro rata share of each item of the corporation for the taxable year, and other information the commissioner requires.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.filing_rule.s_corporation_capital_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "An S corporation files a return for each taxable year in which its federal S election is in effect.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.12, subd. 3(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) An S corporation must file a return with the commissioner for a taxable year during which an election under section 290.9725 is in effect, stating specifically the names and addresses of the persons owning stock in the corporation at any time during the taxable year, the number of shares of stock owned by a shareholder at all times during the taxable year, the shareholder's pro rata share of each item of the corporation for the taxable year, and other information the commissioner requires.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.filing_rule.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "An S corporation files a return for each taxable year in which its federal S election is in effect.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.12, subd. 3(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) An S corporation must file a return with the commissioner for a taxable year during which an election under section 290.9725 is in effect, stating specifically the names and addresses of the persons owning stock in the corporation at any time during the taxable year, the number of shares of stock owned by a shareholder at all times during the taxable year, the shareholder's pro rata share of each item of the corporation for the taxable year, and other information the commissioner requires.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.tax_regime.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Minnesota imposes an annual franchise tax on a corporation whose state contacts produce Minnesota-source gross income.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.02",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An annual franchise tax on the exercise of the corporate franchise to engage in contacts with this state that produce gross income attributable to sources within this state is imposed upon every corporation that so exercises its franchise during the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Minnesota imposes pass-through entity tax on a qualifying entity that makes the annual election, measured by qualifying owners' tax liabilities.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.08, subd. 7a(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Subject to the election in paragraph (b), a pass-through entity tax is imposed on a qualifying entity in an amount equal to the sum of the tax liability of each qualifying owner.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.tax_regime.minimum_fee": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.0922, subd. 1(a)",
          "quote": "(a) In addition to the tax imposed by this chapter without regard to this section, the franchise tax imposed on a corporation required to file under section 289A.08, subdivision 3, other than a corporation treated as an \"S\" corporation under section 290.9725 for the taxable year includes a tax equal to the following amounts:",
          "role": "C-corporation minimum fee",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Minnesota imposes the minimum fee on filing S corporations and partnerships, with a separate included fee for filing C corporations.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.0922, subd. 1(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) A tax is imposed for each taxable year on a corporation required to file a return under section 289A.12, subdivision 3, that is treated as an S corporation under section 290.9725 and on a partnership required to file a return under section 289A.12, subdivision 3, other than a partnership that derives over 80 percent of its income from farming.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MN.llc.tax_regime.s_corporation_built_in_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Minnesota taxes recognized built-in gain of an S corporation with a post-1986 S election at the corporate rate.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9727, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subdivision 1. Tax imposed. For an S corporation electing S corporation status pursuant to section 1362 of the Internal Revenue Code after December 31, 1986, and having a recognized built-in gain as defined in section 1374 of the Internal Revenue Code, there is imposed a tax on the taxable income of such S corporation, as defined in this section, at the rate prescribed by section 290.06, subdivision 1.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MN.llc.tax_regime.s_corporation_capital_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Minnesota imposes an entity tax on a legacy S corporation meeting the pre-1987 election and capital-gain thresholds.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9728, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subdivision 1. Tax imposed. There is imposed a tax on the taxable income of an S corporation that has: (1) elected S corporation status pursuant to section 1362 of the Internal Revenue Code of 1986, as amended through December 31, 1986, before January 1, 1987; (2) a net capital gain for the taxable year (i) in excess of $25,000 and (ii) exceeding 50 percent of the corporation's federal taxable income for the taxable year; and (3) federal taxable income for the taxable year exceeding $25,000.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MN.llc.tax_regime.s_corporation_passive_investment_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Minnesota taxes an S corporation with accumulated C-corporation earnings and profits when passive investment income exceeds 25% of gross receipts.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9729, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subdivision 1. Tax imposed. There is imposed a tax for the taxable year on the taxable income of an S corporation, if for the taxable year an S corporation has: (1) subchapter C earnings and profits at the close of such taxable year; and (2) gross receipts more than 25 percent of which are passive investment income.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.treatment.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.21, subd. 4(b)",
          "quote": "(b) Forty percent of dividends received by a corporation during the taxable year from another corporation in which the recipient owns less than 20 percent of the stock, by vote or value, not including stock described in section 1504(a)(4) of the Internal Revenue Code when the corporate stock with respect to which dividends are paid does not constitute the stock in trade of the taxpayer, or does not constitute property held by the taxpayer primarily for sale to customers in the ordinary course of the taxpayer's trade or business, or when the trade or business of the taxpayer does not consist principally of the holding of the stocks and the collection of income and gain therefrom.",
          "role": "under-20-percent dividend deduction",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.21, subd. 4(a)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a)(1) Fifty percent of dividends received by a corporation during the taxable year from another corporation, in which the recipient owns 20 percent or more of the stock, by vote and value, not including stock described in section 1504(a)(4) of the Internal Revenue Code when the corporate stock with respect to which dividends are paid does not constitute the stock in trade of the taxpayer or would not be included in the inventory of the taxpayer, or does not constitute property held by the taxpayer primarily for sale to customers in the ordinary course of the taxpayer's trade or business, or when the trade or business of the taxpayer does not consist principally of the holding of the stocks and the collection of the income and gains therefrom;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. chapter 290 full text",
          "quote": "For purposes of this chapter, the term \"S corporation\" means any corporation having a valid election in effect for the taxable year under section 1362 of the Internal Revenue Code. An S corporation shall not be subject to the taxes imposed by this chapter, except the taxes imposed under sections 290.0922, 290.92, 290.9727, 290.9728, and 290.9729.",
          "role": "chapter 290 search anchor",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The elective tax uses the sum of each qualifying owner's tax liability; no holding-company or passive-income carve-out was located.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §289A.08, subd. 7a(c); chapters 289A and 290 full text searched",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Subject to the election in paragraph (b), a pass-through entity tax is imposed on a qualifying entity in an amount equal to the sum of the tax liability of each qualifying owner.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6d1dd5a3d4f7eb6cc1ccea597e7ab0857b3fbb874d3c08f837af2d49ac6fdb5a",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.treatment.minimum_fee": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.0922, subd. 3(b)",
          "quote": "(b) \"Minnesota property\" means total Minnesota tangible property as provided in section 290.191, subdivisions 9 to 11, any other tangible property located in Minnesota, but does not include the property of a qualified business as defined under section 469.310, subdivision 11, that is located in a job opportunity building zone designated under section 469.314. Intangible property shall not be included in Minnesota property for purposes of this section.",
          "role": "intangible-property exclusion",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.0922, subd. 2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subd. 2. Exemptions. The following entities are exempt from the tax imposed by this section: (1) corporations exempt from tax under section 290.05; (2) real estate investment trusts; (3) regulated investment companies or a fund thereof; (4) entities having a valid election in effect under section 860D(b) of the Internal Revenue Code; (5) township mutual insurance companies; (6) cooperatives organized under chapter 308A, 308B, or 308C that provide housing exclusively to persons age 55 and over and are classified as homesteads under section 273.124, subdivision 3; and (7) a qualified business as defined under section 469.310, subdivision 11, if for the taxable year all of its property is located in a job opportunity building zone designated under section 469.314 and all of its payroll is a job opportunity building zone payroll under section 469.310.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.treatment.s_corporation_built_in_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The qualifying built-in gain is taxed at the corporate rate notwithstanding the general S-corporation exemption in §290.9725.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9727, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subdivision 1. Tax imposed. For an S corporation electing S corporation status pursuant to section 1362 of the Internal Revenue Code after December 31, 1986, and having a recognized built-in gain as defined in section 1374 of the Internal Revenue Code, there is imposed a tax on the taxable income of such S corporation, as defined in this section, at the rate prescribed by section 290.06, subdivision 1.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.treatment.s_corporation_capital_gains_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.9728, subd. 2",
          "quote": "Subd. 2. Taxable income. For purposes of this section, taxable income means the lesser of: (1) the amount of the net capital gain of the S corporation for the taxable year, as determined under sections 1222 and 1374 of the Internal Revenue Code, and subject to the modifications provided in section 290.0135, in excess of $25,000 that is allocable to this state under section 290.17, 290.191, or 290.20; or",
          "role": "taxable-income base",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "A qualifying legacy S corporation pays entity-level tax at the corporate rate on the lesser statutory capital-gain income base.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9728, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subdivision 1. Tax imposed. There is imposed a tax on the taxable income of an S corporation that has: (1) elected S corporation status pursuant to section 1362 of the Internal Revenue Code of 1986, as amended through December 31, 1986, before January 1, 1987; (2) a net capital gain for the taxable year (i) in excess of $25,000 and (ii) exceeding 50 percent of the corporation's federal taxable income for the taxable year; and (3) federal taxable income for the taxable year exceeding $25,000.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MN.llc.treatment.s_corporation_passive_investment_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Minn. Stat. §290.9729, subd. 2",
          "quote": "Subd. 2. Taxable income. For the purposes of this section, taxable income means the lesser of: (1) the amount of the S corporation's excess net passive income, as determined under section 1375 of the Internal Revenue Code, subject to the provisions of sections 290.0133 to 290.0135, that is allocable to this state under section 290.17, 290.191, or 290.20; or",
          "role": "taxable-income base",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
          "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
          "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "A qualifying S corporation pays entity-level tax at the corporate rate on the lesser statutory excess-net-passive-income base.",
      "fetch_event_id": null,
      "pinpoint": "Minn. Stat. §290.9729, subd. 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Subdivision 1. Tax imposed. There is imposed a tax for the taxable year on the taxable income of an S corporation, if for the taxable year an S corporation has: (1) subchapter C earnings and profits at the close of such taxable year; and (2) gross receipts more than 25 percent of which are passive investment income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MN/snapshots/c50/MN/6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6fce54f9d54ebe592ef91cf7e42858abce344f82e58fc691bdbf2b5bd9b4bc0c",
      "source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MO.llc.base_tax_locator.affected_business_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The partnership and S-corporation ABE bases and rate reference are located at § 143.436.3-.4.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.436.3",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The sum of the separately and nonseparately computed income and deduction items, as described in 26 U.S.C. Section 702(a), of the affected business entity, to the extent derived from or connected with sources within this state, as determined pursuant to section 143.455, shall be decreased by the percentage deduction that would be allowable to the owners under section 143.022, and increased or decreased by any modification made pursuant to sections 143.121 and 143.141 that relates to an item of the affected business entity's income, gain, loss, or deduction, to the extent derived from or connected with sources within this state, as determined pursuant to section 143.455. The resulting amount shall be the partnership's Missouri net income or loss, which, if greater than zero, shall be multiplied by the highest rate of tax used to determine a Missouri income tax liability for an individual pursuant to section 143.011 to arrive at the tax due.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MO.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mo. Rev. Stat. § 143.071.3",
          "quote": "For all tax years beginning on or after January 1, 2020, a tax is hereby imposed upon the Missouri taxable income of corporations in an amount equal to four percent of Missouri taxable income.",
          "role": "rate_locator",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-071.html",
          "source_sha256": "dcc8281cda0aa36a376c78d43461e16069d1c5486a34032b2430c728aa1a7058",
          "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.071"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The corporation-income base is located at § 143.431.1 and the current rate at § 143.071.3.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.431.1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The Missouri taxable income of a corporation taxable under sections 143.011 to 143.996 shall be so much of its federal taxable income for the taxable year, with the modifications specified in subsections 2 to 4 of this section, as is derived from sources within Missouri as provided in section 143.451. The tax of a corporation shall be computed on its Missouri taxable income at the rates provided in section 143.071.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
      "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MO.llc.does_not_reach.affected_business_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mo. Rev. Stat. § 143.436.2(1)",
          "quote": "\"Affected business entity\", any partnership or S corporation that elects to be subject to tax pursuant to subsection 11 of this section;",
          "role": "affected_entity_limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
          "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
          "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436"
        },
        {
          "pinpoint": "Mo. Rev. Stat. § 143.436.2(5)",
          "quote": "\"Partnership\", the same meaning as provided in 26 U.S.C. Section 7701(a)(2), but not including a publicly traded partnership. The term partnership shall include a limited liability company that is treated as a partnership for federal income tax purposes;",
          "role": "publicly_traded_partnership_exclusion",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
          "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
          "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.436.2(1), (5)-(6), .5(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "If an affected business entity is a direct or indirect member of another affected business entity, the member affected business entity shall, when calculating its Missouri net income or loss pursuant to subsection 3 or 4 of this section, subtract its distributive share of Missouri net income or add its distributive share of Missouri net loss from the affected business entity in which it is a direct or indirect member.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MO.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.471.1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An S corporation, as defined by Section 1361 (a)(1) of the Internal Revenue Code, shall not be subject to the taxes imposed by section 143.071, or other sections imposing income tax on corporations.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
      "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MO.llc.effective_period.affected_business_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The affected-business-entity tax applies only to tax years ending on or after December 31, 2022.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.436.14",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The provisions of this section shall only apply to tax years ending on or after December 31, 2022.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MO.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The current corporation-income provision applies to tax years beginning on or after January 1, 2020.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.071.3",
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      "publish_status": "publish_ready",
      "quote": "For all tax years beginning on or after January 1, 2020, a tax is hereby imposed upon the Missouri taxable income of corporations in an amount equal to four percent of Missouri taxable income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-071.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "dcc8281cda0aa36a376c78d43461e16069d1c5486a34032b2430c728aa1a7058",
      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.071",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MO.llc.filing_rule.affected_business_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mo. Rev. Stat. § 143.436.11",
          "quote": "A partnership or an S corporation may elect to become an affected business entity that is required to pay the tax pursuant to this section. A separate election shall be made for each tax year. Such election shall be made on such form and in such manner as the director of revenue may prescribe by rule.",
          "role": "annual_election_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
          "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
          "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "An ABE files an affected-business-entity tax return for each subject year, and a separate prescribed election is required for every tax year.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.436.7, .11",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For each tax year in which it is subject to a tax under this section, the affected business entity shall file an affected business entity tax return on a date prescribed by the director of revenue.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
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      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MO.llc.filing_rule.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mo. Rev. Stat. § 143.511",
          "quote": "Income tax returns required by sections 143.011 to 143.996 shall be filed on or before the fifteenth day of the fourth month following the close of the taxpayer's taxable year except where the taxpayer is an exempt organization.",
          "role": "filing_deadline",
          "snapshot_path": "rigs/entity-research/corp-lp/snapshots/MO/657254b7db1fa26cbee4b1a0baf84eadeca1d577a6a7eaceb7b6612ffe0a63e9.html",
          "source_sha256": "657254b7db1fa26cbee4b1a0baf84eadeca1d577a6a7eaceb7b6612ffe0a63e9",
          "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.511"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.481(6)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every corporation which: (a) Is not an exempt corporation described in subsection 2 of section 143.441; (b) Is required to file a federal income tax return; and (c) Has gross income from sources within this state of one hundred dollars or more.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/MO/7ca8b627956ed29558d896948640b5d1c2eaf27c200933439a1bdccc16bff014.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7ca8b627956ed29558d896948640b5d1c2eaf27c200933439a1bdccc16bff014",
      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.481",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MO.llc.tax_regime.affected_business_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mo. Rev. Stat. § 143.436.4(1)",
          "quote": "Notwithstanding any provision of law to the contrary, a tax is hereby imposed on each affected business entity that is an S corporation and that is doing business in this state.",
          "role": "s_corporation_imposition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
          "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
          "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Missouri imposes the SALT Parity Act tax on each electing affected partnership or S corporation doing business in the state.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.436.3-.4",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Notwithstanding any provision of law to the contrary, a tax is hereby imposed on each affected business entity that is a partnership and that is doing business in this state.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MO.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.071.3",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For all tax years beginning on or after January 1, 2020, a tax is hereby imposed upon the Missouri taxable income of corporations in an amount equal to four percent of Missouri taxable income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-071.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "dcc8281cda0aa36a376c78d43461e16069d1c5486a34032b2430c728aa1a7058",
      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.071",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MO.llc.treatment.affected_business_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mo. Rev. Stat. § 143.436.3(1)",
          "quote": "The sum of the separately and nonseparately computed income and deduction items, as described in 26 U.S.C. Section 702(a), of the affected business entity, to the extent derived from or connected with sources within this state, as determined pursuant to section 143.455, shall be decreased by the percentage deduction that would be allowable to the owners under section 143.022, and increased or decreased by any modification made pursuant to sections 143.121 and 143.141 that relates to an item of the affected business entity's income, gain, loss, or deduction, to the extent derived from or connected with sources within this state, as determined pursuant to section 143.455. The resulting amount shall be the partnership's Missouri net income or loss, which, if greater than zero, shall be multiplied by the highest rate of tax used to determine a Missouri income tax liability for an individual pursuant to section 143.011 to arrive at the tax due.",
          "role": "base_incorporating_section_143_455",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
          "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
          "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436"
        },
        {
          "pinpoint": "Mo. Rev. Stat. § 143.455.7(3)",
          "quote": "Capital gains and losses from sales of intangible personal property are allocable to this state if the corporation's commercial domicile is in this state.",
          "role": "incorporated_intangible_gain_allocation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
          "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
          "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v"
        },
        {
          "pinpoint": "Mo. Rev. Stat. § 143.455.8",
          "quote": "Interest and dividends are allocable to this state if the corporation's commercial domicile is in this state.",
          "role": "incorporated_interest_dividend_allocation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
          "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
          "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v"
        },
        {
          "pinpoint": "Mo. Rev. Stat. § 143.455.9(1)",
          "quote": "Patent and copyright royalties are allocable to this state: (a) If and to the extent that the patent or copyright is utilized by the payer in this state; or (b) If and to the extent that the patent or copyright is utilized by the payer in a state in which the corporation is not taxable and the corporation's commercial domicile is in this state.",
          "role": "incorporated_royalty_allocation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
          "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
          "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The ABE base uses holding-receipt source allocation and removes another ABE's distributive Missouri net income, or adds its distributive Missouri net loss.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. § 143.436.3, .5(1); § 143.455.7-.9",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "If an affected business entity is a direct or indirect member of another affected business entity, the member affected business entity shall, when calculating its Missouri net income or loss pursuant to subsection 3 or 4 of this section, subtract its distributive share of Missouri net income or add its distributive share of Missouri net loss from the affected business entity in which it is a direct or indirect member.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/mo-stat-143-436.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "932c7152a63958cbe9adab0ce72cf33378281b08ff3145e00bf0cd4f089281a2",
      "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MO.llc.treatment.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mo. Rev. Stat. § 143.455.7(3)",
          "quote": "Capital gains and losses from sales of intangible personal property are allocable to this state if the corporation's commercial domicile is in this state.",
          "role": "intangible_gain_allocation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
          "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
          "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v"
        },
        {
          "pinpoint": "Mo. Rev. Stat. § 143.455.8",
          "quote": "Interest and dividends are allocable to this state if the corporation's commercial domicile is in this state.",
          "role": "interest_dividend_allocation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
          "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
          "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v"
        },
        {
          "pinpoint": "Mo. Rev. Stat. § 143.455.9(1)",
          "quote": "Patent and copyright royalties are allocable to this state: (a) If and to the extent that the patent or copyright is utilized by the payer in this state; or (b) If and to the extent that the patent or copyright is utilized by the payer in a state in which the corporation is not taxable and the corporation's commercial domicile is in this state.",
          "role": "royalty_allocation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
          "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
          "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A corporate-classified holding LLC remains within the regime, while corporate dividends and other holding receipts receive the stated subtraction and source-allocation treatment.",
      "fetch_event_id": null,
      "pinpoint": "Mo. Rev. Stat. §§ 143.431.2, 143.455.7-.9",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There shall be subtracted, to the extent included in federal taxable income, corporate dividends from sources within Missouri.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MO/snapshots/MO/980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "980d74bc5eb241acddb31afb7a083d7162579eb7177a641b5b3e1a2079be2658",
      "source_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.base_tax_locator.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Miss. Code § 27-13-7(1)(a)",
          "quote": "Except as otherwise provided in subsections (3), (4), (5) and (7) of this section, there is hereby imposed, levied and assessed upon every corporation, association or joint-stock company, or partnership treated as a corporation under the income tax laws or regulations as hereinbefore defined, organized and existing under and by virtue of the laws of some other state, territory or country, or organized and existing without any specific statutory authority, now or hereafter doing business or exercising any power, privilege or right within this state",
          "role": "foreign-entity base",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-msleg-sb2858-franchise-tax-phaseout.html",
          "source_sha256": "9d6c564a82898049a9b480dc85f4748a28b024648079ccc7881bf8b858a9ada1",
          "source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The domestic and foreign franchise-tax bases are located in §§27-13-5 and 27-13-7; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "SB 2858 (2016), §§ 3-4 amending Miss. Code §§ 27-13-5 and 27-13-7",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as otherwise provided in subsections (3), (4), (5) and (7) of this section, there is hereby imposed, to be paid and collected as hereinafter provided, a franchise or excise tax upon every corporation, association or joint-stock company or partnership treated as a corporation under the income tax laws or regulations, organized or created for pecuniary gain, having privileges not possessed by individuals, and having authorized capital stock now existing in this state, or hereafter organized, created or established, under and by virtue of the laws of the State of Mississippi",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-msleg-sb2858-franchise-tax-phaseout.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9d6c564a82898049a9b480dc85f4748a28b024648079ccc7881bf8b858a9ada1",
      "source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The corporate income-tax base and rate are located in Miss. Code §27-7-5; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "SB 2858 (2016), § 1 amending Miss. Code § 27-7-5(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There is hereby assessed and levied, to be collected and paid as hereinafter provided, for the calendar year 1983 and fiscal years ending during the calendar year 1983 and all taxable years thereafter, upon the entire net income of every resident individual, corporation, association, trust or estate, in excess of the credits provided, a tax at the following rates:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-msleg-sb2858-franchise-tax-phaseout.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9d6c564a82898049a9b480dc85f4748a28b024648079ccc7881bf8b858a9ada1",
      "source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.base_tax_locator.elective_pte_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The election and entity-level payment rule are in §27-7-26, which applies the tax imposed under chapter 7; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "HB 1668 (2023), § 1 amending Miss. Code § 27-7-26(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For calendar year 2022, and for each calendar year thereafter, any partnership, S corporation or similar pass-through entity may elect to be taxed as an electing pass-through entity and pay the tax imposed under this chapter at the entity level. For the purposes of this section, the term \"electing pass-through entity\" means a partnership, S corporation or similar pass-through entity that has made an election pursuant to this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/c50/MS/3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7",
      "source_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.does_not_reach.corporate_franchise_tax": {
      "additional_sources": [],
      "capture_date": "2026-10-06",
      "claim_type": "operative official revenue instruction or regulation",
      "display": "The holding-company exclusion is limited to the calculated portion of capital attributable to stock or securities of a subsidiary corporation.",
      "fetch_event_id": null,
      "pinpoint": "2025 Form 83-100 instructions, Holding Corporation; Form 83-110 line 7",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Per Miss. Ann. Code §27-13-1(i), in the case of a holding\ncorporation, the value of the capital used, invested or\nemployed in this state shall exclude that portion of the book\nvalue of the holding corporation’s investment in stock or\nsecurities of its subsidiary corporation using the ratio between\n(1) the holding corporation’s investment in stock or securities\nof its subsidiary corporation and (2) the holding corporation’s\ntotal assets. Such ratio shall then be applied to the total capital\nstock, surplus, undivided profits and true reserves of the\nholding corporation in order to arrive at the amount of the\nexclusion. The holding company exclusion is computed on line\n7 of Form 83-110 and a schedule of computation must be\nattached to the return for the exclusion.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/319588af52ce61eb602d224ad9b1fb19ea7569e42149d3e86b03b19818b08a5b.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "319588af52ce61eb602d224ad9b1fb19ea7569e42149d3e86b03b19818b08a5b",
      "source_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20CIT%20INSTRUCTIONS%2083-100%20-%20Final%20%2001.14.2026.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "official DOR limit on passive-income allocation procedure",
      "display": "The stated allocation procedure is limited to nonbusiness income and wholly passive investment income from outside Mississippi and requires supporting explanation.",
      "fetch_event_id": null,
      "pinpoint": "Mississippi DOR Business Tax FAQ, wholly passive investment income",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A statement must be included to outline the reasons that the income, loss, expenses, or deductions is being allocated. Wholly passive investment income from outside of Mississippi will be considered only with an attached detailed explanation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-dor-business-tax-faq.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "5795560ccb8e1df6270870a5e8729a13b8926e419100b82888abc441dbe7ae21",
      "source_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.does_not_reach.elective_pte_tax": {
      "additional_sources": [
        {
          "pinpoint": "Notice 80-23-002, Eligibility for the Pass-Through Entity Election",
          "quote": "Eligibility for the Pass-Through Entity Election\nFor calendar year 2022 and each calendar year thereafter, any partnership, S corporation or similar pass-through\nentity desiring to be taxed as an electing pass-through entity (“electing PTE”) must have a vote satisfying the\nthreshold required for taking official actions as specified within the entity’s governing documents. If the entity’s\ngoverning documents do not contain any such provisions for the approval of official actions, the election shall then\nbe accomplished by a vote or written consent of the owners, members, partners or shareholders holding greater\nthan fifty percent (50%) of the voting control of the entity, and also if the entity has a governing body, by vote or\nwritten consent of the members of the governing body of the entity. Fiduciaries are not eligible to make a pass-\nthrough entity election.",
          "role": "general_election_eligibility",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/abd380dae7d94e0b569667ff763f9ed075ba84426ef725c2886c4ed768a396f7.pdf",
          "source_sha256": "abd380dae7d94e0b569667ff763f9ed075ba84426ef725c2886c4ed768a396f7",
          "source_url": "https://www.dor.ms.gov/sites/default/files/notices-technical-bulletins/Pass-Through%2520Entity%2520Revised%2520Election%2520Notice%25204-13-23.pdf"
        },
        {
          "pinpoint": "2025 Form 84-100 instructions, Form 84-105 lines 5-6",
          "quote": "INCOME TAX\n(COMPOSITE AND ELECTING PASS-THROUGH ENTITIES)\nLine 5: Mississippi net taxable income is only entered on this line\nif the taxpayer is filing a composite or electing passthrough entity return or is required to make a payment of\ntax because it failed to obtain an agreement from a nonresident shareholder required by subsection (3)(a) of\nsection 10 of the Mississippi S Corporation Income Tax\nAct. In these situations, enter the total of the non-resident\nshareholders' distributions included in the composite\nreturn from Line 32, Form 84-122 or the total of the electing\npass-through entity income from Line 35, Form 84-122. If\napplicable, enter the income on which payment of tax is\nrequired by the S Corporation for failure to secure the\nabove-mentioned agreement.\nLine 6: Composite or electing pass-through entities, enter the\namount of income tax due. For tax year 2025, the income\ntax rates are: 0% on the first $5,000 of taxable income; 4%\non the next $5,000 of taxable income; and 5% on taxable\nincome in excess of $10,000.",
          "role": "electing_pte_income_base",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4.pdf",
          "source_sha256": "0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4",
          "source_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20PTE%20INSTRUCTIONS%2084-100%20-%20Final%20%2001.14.2026.pdf"
        },
        {
          "pinpoint": "2025 Form 84-100 instructions, Form 84-122 line 35",
          "quote": "Line 35: Mississippi electing pass-through entity income\nsubject to tax (line 33 less line 34). If positive, report\nthis amount on Form 84-105, line 5. If negative, enter\nzero on Form 84-105, line 5.",
          "role": "electing_pte_income_subject_to_tax",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4.pdf",
          "source_sha256": "0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4",
          "source_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20PTE%20INSTRUCTIONS%2084-100%20-%20Final%20%2001.14.2026.pdf"
        },
        {
          "pinpoint": "2025 Form 84-100 instructions, franchise-tax section, Form 84-110 line 7",
          "quote": "Holding Corporation: A holding corporation, as defined in Miss.\nAnn. Code §27-13-1(i), is (1) any corporation owning at least\neighty percent (80%) of the value of capital stock and at least\neighty percent (80%) of the combined voting power of all classes\nof capital stock of another corporation and (2) deriving at least\nninety-five percent (95%) of its gross receipts from dividends,\ninterest, royalties, rents, services provided to members of an\naffiliated group (as defined in Section 27-7- 37(2)(d)) to the extent\nof the cost of providing such services.\nPer Miss. Ann. Code §27-13-1(i), in the case of a holding\ncorporation, the value of the capital used, invested or employed\nin this state shall exclude that portion of the book value of the\nholding corporation’s investment in stock or securities of its\nsubsidiary corporation using the ratio between (1) the holding\ncorporation’s investment in stock or securities of its subsidiary\ncorporation and (2) the holding corporation’s total assets. Such\nratio shall then be applied to the total capital stock, surplus,\nundivided profits, and true reserves of the holding corporation in\norder to arrive at the amount of the exclusion. The holding\ncompany exclusion is computed on line 7 of Form 84-110 and a\nschedule of computation must be attached to the return for the\nexclusion.",
          "role": "holding_corporation_franchise_rule_outside_elective_income_scope",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4.pdf",
          "source_sha256": "0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4",
          "source_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20PTE%20INSTRUCTIONS%2084-100%20-%20Final%20%2001.14.2026.pdf"
        },
        {
          "pinpoint": "35 Miss. Admin. Code 35.III.2.04.100",
          "quote": "Chapter 04 Interest Income\n\n100    Interest received by or credited to the taxpayer constitutes gross income and is fully\n       taxable, unless specifically exempt or excluded by statute. Interest income includes but is\n       not limited to, interest on savings or other bank deposits; interest on coupon bonds; interest\n       on an open account, a promissory note, a mortgage, or a corporate bond or debenture; the\n       interest portion of a condemnation award; usurious interest; interest on legacies; and\n       interest on life insurance proceeds held under an agreement to pay interest thereon.",
          "role": "current_income_categories",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/e17952fdc2bcf0d7430ae0e13beee452609610f45af63027fb280b884197f1b8.pdf",
          "source_sha256": "e17952fdc2bcf0d7430ae0e13beee452609610f45af63027fb280b884197f1b8",
          "source_url": "https://www.sos.ms.gov/adminsearch/ACCode/00000158c.pdf"
        },
        {
          "pinpoint": "35 Miss. Admin. Code 35.III.2.06.100-.103",
          "quote": "Chapter 06 Dividend Income\n\n100    Dividends are included in gross income unless specifically excluded under Miss. Code\n       Ann. Section 27-7-15(4)(i).\n\n101    The term \"dividend\" for the purpose of the Mississippi Income Tax Law means any\n       distribution of property in the ordinary course of business, even though extraordinary in\n       amount, made by a domestic or foreign corporation to its shareholders out of earnings and\n       profit.\n\n102    The earnings and profits of the taxable year shall be computed as of the close of such year,\n       without reduction by reason of any distributions made during the taxable year. Liquidating\n       dividends do not have the status of dividends for Mississippi income tax purposes. Such\n       distributions constitute a return of investment and the gain or loss realized or sustained is\n       one of capital.\n\n103    Dividends must be included in gross income of the shareholder if such dividends have not\n       already borne a tax in Mississippi or another state prior to the receipt of same by such\n       shareholders.",
          "role": "current_dividend_rule",
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          "source_sha256": "e17952fdc2bcf0d7430ae0e13beee452609610f45af63027fb280b884197f1b8",
          "source_url": "https://www.sos.ms.gov/adminsearch/ACCode/00000158c.pdf"
        },
        {
          "pinpoint": "HB 1668 (2023), § 1 amending Miss. Code § 27-7-26(2)",
          "quote": "For calendar\r\nyear 2022, and for each calendar year thereafter, any partnership, S corporation\r\nor similar pass-through entity may elect to be taxed as an electing pass-through\r\nentity and pay the tax imposed under this chapter at the entity level.",
          "role": "enacted_section_anchor",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7.html",
          "source_sha256": "3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7",
          "source_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm"
        }
      ],
      "capture_date": "2026-10-06",
      "claim_type": "closest_official_passage_for_official_record_silent",
      "display": null,
      "fetch_event_id": null,
      "pinpoint": "Notice 80-23-002, Filing an Electing Pass-Through Entity Return",
      "public_reason": "The official record does not state this",
      "publish_status": "typed_unknown",
      "quote": "Filing an Electing Pass-Through Entity Return\nAn electing PTE will file the Pass-Through Entity Tax Return, form 84-105, and check the “Electing Pass-Through\nEntity” check box in order to be taxed at the entity level. A copy of the Pass-Through Entity Election Form, form\n84-381, should also be attached to the return.",
      "readiness": "official_record_silent",
      "reason_code": "value_not_stated_in_source",
      "rendered": "badge",
      "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/abd380dae7d94e0b569667ff763f9ed075ba84426ef725c2886c4ed768a396f7.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "abd380dae7d94e0b569667ff763f9ed075ba84426ef725c2886c4ed768a396f7",
      "source_url": "https://www.dor.ms.gov/sites/default/files/notices-technical-bulletins/Pass-Through%2520Entity%2520Revised%2520Election%2520Notice%25204-13-23.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.effective_period.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The corporation franchise tax law is repealed from and after January 1, 2028.",
      "fetch_event_id": null,
      "pinpoint": "SB 2858 (2016), § 5",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sections 27-13-1, 27-13-3, 27-13-5, 27-13-7, 27-13-8, 27-13-9, 27-13-11, 27-13-13, 27-13-15, 27-13-17, 27-13-19, 27-13-21, 27-13-23, 27-13-25, 27-13-27, 27-13-29, 27-13-31, 27-13-33, 27-13-35, 27-13-37, 27-13-39, 27-13-41, 27-13-47, 27-13-49, 27-13-51, 27-13-53, 27-13-55, 27-13-57, 27-13-59, 27-13-61, 27-13-63, 27-13-65 and 27-13-67, Mississippi Code of 1972, which are the corporation franchise tax law, are repealed from and after January 1, 2028.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-msleg-sb2858-franchise-tax-phaseout.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9d6c564a82898049a9b480dc85f4748a28b024648079ccc7881bf8b858a9ada1",
      "source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The cited imposition applies to the listed calendar and fiscal years and ‘all taxable years thereafter.’",
      "fetch_event_id": null,
      "pinpoint": "SB 2858 (2016), § 1 amending Miss. Code § 27-7-5(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There is hereby assessed and levied, to be collected and paid as hereinafter provided, for the calendar year 1983 and fiscal years ending during the calendar year 1983 and all taxable years thereafter, upon the entire net income of every resident individual, corporation, association, trust or estate, in excess of the credits provided, a tax at the following rates:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-msleg-sb2858-franchise-tax-phaseout.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9d6c564a82898049a9b480dc85f4748a28b024648079ccc7881bf8b858a9ada1",
      "source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.effective_period.elective_pte_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The elective entity-level regime applies for calendar year 2022 and each calendar year thereafter.",
      "fetch_event_id": null,
      "pinpoint": "HB 1668 (2023), § 1 amending Miss. Code § 27-7-26(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For calendar year 2022, and for each calendar year thereafter, any partnership, S corporation or similar pass-through entity may elect to be taxed as an electing pass-through entity and pay the tax imposed under this chapter at the entity level. For the purposes of this section, the term \"electing pass-through entity\" means a partnership, S corporation or similar pass-through entity that has made an election pursuant to this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/c50/MS/3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7",
      "source_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.filing_rule.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "official DOR filing guidance",
      "display": "The corporate income and franchise tax return is due on the fifteenth day of the fourth month after the taxable year closes.",
      "fetch_event_id": null,
      "pinpoint": "Mississippi DOR Business Tax FAQ, return due dates",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The C Corporation income and franchise tax return is due on or before the 15th day of the 4th month following the close of the taxable year. PTE returns are due on or before the 15th day of the 3rd month following the close of the taxable year. Mississippi will follow federal return filing and extended filing due dates.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-dor-business-tax-faq.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "5795560ccb8e1df6270870a5e8729a13b8926e419100b82888abc441dbe7ae21",
      "source_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.filing_rule.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Business Tax FAQ, LLC classification",
          "quote": "A domestic or foreign limited liability company (“LLC”) is classified as an entity for purposes of Mississippi income tax laws in the same manner as the entity is classified for federal income tax purposes. If an LLC is treated as a partnership for federal income tax purposes, it will file as a pass-through entity for Mississippi purposes. If an LLC is treated as a corporation for federal income tax purposes, it will file as a corporation for Mississippi income and franchise tax purposes.",
          "role": "LLC coverage",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-dor-business-tax-faq.html",
          "source_sha256": "5795560ccb8e1df6270870a5e8729a13b8926e419100b82888abc441dbe7ae21",
          "source_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "official DOR filing guidance",
      "display": "A corporation must file a corporate income and franchise tax return even when inactive; DOR places a federally corporate LLC in this branch.",
      "fetch_event_id": null,
      "pinpoint": "Mississippi DOR Business Tax FAQ, ‘Who is required to file a corporate tax return?’",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "All corporations, associations, or entities doing business, earning income, or existing in Mississippi are required to file a corporate income and franchise tax return. Every corporation, domesticated or qualified to do business in Mississippi must file a return even if the corporation is inactive or not engaged in business.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-dor-business-tax-faq.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "5795560ccb8e1df6270870a5e8729a13b8926e419100b82888abc441dbe7ae21",
      "source_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.filing_rule.elective_pte_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "official DOR filing guidance",
      "display": "An electing PTE files Form 84-105, checks the electing-PTE box, and attaches Form 84-381.",
      "fetch_event_id": null,
      "pinpoint": "Mississippi DOR Updated Electing Pass-Through Entity FAQs (March 4, 2024), p. 2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An electing pass-through entity will file the Pass-Through Entity Tax Return, form 84-105, and check the “Electing Pass-Through Entity” check box. A copy of the Pass-Through Entity Election Form, form 84-381, should also be attached to the return.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/c50/MS/cf91a9b9bb0cb2844bc2fd1498b0bb849d7eb9c78fcc5a56c9903b0adc405666.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "cf91a9b9bb0cb2844bc2fd1498b0bb849d7eb9c78fcc5a56c9903b0adc405666",
      "source_url": "https://www.dor.ms.gov/sites/default/files/business/Updated%20EPTE%20FAQ.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.tax_regime.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "SB 2858 (2016), § 4 amending Miss. Code § 27-13-7(1)(a)",
          "quote": "Except as otherwise provided in subsections (3), (4), (5) and (7) of this section, there is hereby imposed, levied and assessed upon every corporation, association or joint-stock company, or partnership treated as a corporation under the income tax laws or regulations as hereinbefore defined, organized and existing under and by virtue of the laws of some other state, territory or country, or organized and existing without any specific statutory authority, now or hereafter doing business or exercising any power, privilege or right within this state",
          "role": "foreign-entity imposition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-msleg-sb2858-franchise-tax-phaseout.html",
          "source_sha256": "9d6c564a82898049a9b480dc85f4748a28b024648079ccc7881bf8b858a9ada1",
          "source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "Mississippi imposes a franchise or excise tax on domestic and foreign corporations and partnerships treated as corporations.",
      "fetch_event_id": null,
      "pinpoint": "SB 2858 (2016), § 3 amending Miss. Code § 27-13-5(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as otherwise provided in subsections (3), (4), (5) and (7) of this section, there is hereby imposed, to be paid and collected as hereinafter provided, a franchise or excise tax upon every corporation, association or joint-stock company or partnership treated as a corporation under the income tax laws or regulations, organized or created for pecuniary gain, having privileges not possessed by individuals, and having authorized capital stock now existing in this state, or hereafter organized, created or established, under and by virtue of the laws of the State of Mississippi",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-msleg-sb2858-franchise-tax-phaseout.html",
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      "source_sha256": "9d6c564a82898049a9b480dc85f4748a28b024648079ccc7881bf8b858a9ada1",
      "source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.tax_regime.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Business Tax FAQ, LLC classification",
          "quote": "A domestic or foreign limited liability company (“LLC”) is classified as an entity for purposes of Mississippi income tax laws in the same manner as the entity is classified for federal income tax purposes. If an LLC is treated as a partnership for federal income tax purposes, it will file as a pass-through entity for Mississippi purposes. If an LLC is treated as a corporation for federal income tax purposes, it will file as a corporation for Mississippi income and franchise tax purposes.",
          "role": "LLC coverage",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-dor-business-tax-faq.html",
          "source_sha256": "5795560ccb8e1df6270870a5e8729a13b8926e419100b82888abc441dbe7ae21",
          "source_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "Mississippi imposes income tax on corporate net income; an LLC reaches this filing branch when classified federally as a corporation.",
      "fetch_event_id": null,
      "pinpoint": "SB 2858 (2016), § 1 amending Miss. Code § 27-7-5(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There is hereby assessed and levied, to be collected and paid as hereinafter provided, for the calendar year 1983 and fiscal years ending during the calendar year 1983 and all taxable years thereafter, upon the entire net income of every resident individual, corporation, association, trust or estate, in excess of the credits provided, a tax at the following rates:",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-msleg-sb2858-franchise-tax-phaseout.html",
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      "source_class": "S1",
      "source_sha256": "9d6c564a82898049a9b480dc85f4748a28b024648079ccc7881bf8b858a9ada1",
      "source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.tax_regime.elective_pte_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "A partnership, S corporation, or similar pass-through entity may elect to pay Mississippi income tax at the entity level.",
      "fetch_event_id": null,
      "pinpoint": "HB 1668 (2023), § 1 amending Miss. Code § 27-7-26(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For calendar year 2022, and for each calendar year thereafter, any partnership, S corporation or similar pass-through entity may elect to be taxed as an electing pass-through entity and pay the tax imposed under this chapter at the entity level. For the purposes of this section, the term \"electing pass-through entity\" means a partnership, S corporation or similar pass-through entity that has made an election pursuant to this section.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/c50/MS/3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7.html",
      "snapshot_resolved": true,
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      "source_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.treatment.corporate_franchise_tax": {
      "additional_sources": [],
      "capture_date": "2026-10-06",
      "claim_type": "operative official revenue instruction or regulation",
      "display": "A qualifying holding corporation computes an exclusion from capital for the stated portion of its investment in subsidiary stock or securities.",
      "fetch_event_id": null,
      "pinpoint": "2025 Form 83-100 instructions, Holding Corporation; Form 83-110 line 7",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Per Miss. Ann. Code §27-13-1(i), in the case of a holding\ncorporation, the value of the capital used, invested or\nemployed in this state shall exclude that portion of the book\nvalue of the holding corporation’s investment in stock or\nsecurities of its subsidiary corporation using the ratio between\n(1) the holding corporation’s investment in stock or securities\nof its subsidiary corporation and (2) the holding corporation’s\ntotal assets. Such ratio shall then be applied to the total capital\nstock, surplus, undivided profits and true reserves of the\nholding corporation in order to arrive at the amount of the\nexclusion. The holding company exclusion is computed on line\n7 of Form 83-110 and a schedule of computation must be\nattached to the return for the exclusion.",
      "readiness": "ready",
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      "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/319588af52ce61eb602d224ad9b1fb19ea7569e42149d3e86b03b19818b08a5b.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "319588af52ce61eb602d224ad9b1fb19ea7569e42149d3e86b03b19818b08a5b",
      "source_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20CIT%20INSTRUCTIONS%2083-100%20-%20Final%20%2001.14.2026.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "official DOR passive-income allocation guidance",
      "display": "DOR treats the identified passive out-of-state investment income through a separate allocation and documentation procedure, not as an entity exemption.",
      "fetch_event_id": null,
      "pinpoint": "Mississippi DOR Business Tax FAQ, wholly passive investment income",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A statement must be included to outline the reasons that the income, loss, expenses, or deductions is being allocated. Wholly passive investment income from outside of Mississippi will be considered only with an attached detailed explanation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MS/snapshots/ms-dor-business-tax-faq.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "5795560ccb8e1df6270870a5e8729a13b8926e419100b82888abc441dbe7ae21",
      "source_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MS.llc.treatment.elective_pte_tax": {
      "additional_sources": [
        {
          "pinpoint": "Notice 80-23-002, Eligibility for the Pass-Through Entity Election",
          "quote": "Eligibility for the Pass-Through Entity Election\nFor calendar year 2022 and each calendar year thereafter, any partnership, S corporation or similar pass-through\nentity desiring to be taxed as an electing pass-through entity (“electing PTE”) must have a vote satisfying the\nthreshold required for taking official actions as specified within the entity’s governing documents. If the entity’s\ngoverning documents do not contain any such provisions for the approval of official actions, the election shall then\nbe accomplished by a vote or written consent of the owners, members, partners or shareholders holding greater\nthan fifty percent (50%) of the voting control of the entity, and also if the entity has a governing body, by vote or\nwritten consent of the members of the governing body of the entity. Fiduciaries are not eligible to make a pass-\nthrough entity election.",
          "role": "general_election_eligibility",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/abd380dae7d94e0b569667ff763f9ed075ba84426ef725c2886c4ed768a396f7.pdf",
          "source_sha256": "abd380dae7d94e0b569667ff763f9ed075ba84426ef725c2886c4ed768a396f7",
          "source_url": "https://www.dor.ms.gov/sites/default/files/notices-technical-bulletins/Pass-Through%2520Entity%2520Revised%2520Election%2520Notice%25204-13-23.pdf"
        },
        {
          "pinpoint": "2025 Form 84-100 instructions, Form 84-105 lines 5-6",
          "quote": "INCOME TAX\n(COMPOSITE AND ELECTING PASS-THROUGH ENTITIES)\nLine 5: Mississippi net taxable income is only entered on this line\nif the taxpayer is filing a composite or electing passthrough entity return or is required to make a payment of\ntax because it failed to obtain an agreement from a nonresident shareholder required by subsection (3)(a) of\nsection 10 of the Mississippi S Corporation Income Tax\nAct. In these situations, enter the total of the non-resident\nshareholders' distributions included in the composite\nreturn from Line 32, Form 84-122 or the total of the electing\npass-through entity income from Line 35, Form 84-122. If\napplicable, enter the income on which payment of tax is\nrequired by the S Corporation for failure to secure the\nabove-mentioned agreement.\nLine 6: Composite or electing pass-through entities, enter the\namount of income tax due. For tax year 2025, the income\ntax rates are: 0% on the first $5,000 of taxable income; 4%\non the next $5,000 of taxable income; and 5% on taxable\nincome in excess of $10,000.",
          "role": "electing_pte_income_base",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4.pdf",
          "source_sha256": "0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4",
          "source_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20PTE%20INSTRUCTIONS%2084-100%20-%20Final%20%2001.14.2026.pdf"
        },
        {
          "pinpoint": "2025 Form 84-100 instructions, Form 84-122 line 35",
          "quote": "Line 35: Mississippi electing pass-through entity income\nsubject to tax (line 33 less line 34). If positive, report\nthis amount on Form 84-105, line 5. If negative, enter\nzero on Form 84-105, line 5.",
          "role": "electing_pte_income_subject_to_tax",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4.pdf",
          "source_sha256": "0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4",
          "source_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20PTE%20INSTRUCTIONS%2084-100%20-%20Final%20%2001.14.2026.pdf"
        },
        {
          "pinpoint": "2025 Form 84-100 instructions, franchise-tax section, Form 84-110 line 7",
          "quote": "Holding Corporation: A holding corporation, as defined in Miss.\nAnn. Code §27-13-1(i), is (1) any corporation owning at least\neighty percent (80%) of the value of capital stock and at least\neighty percent (80%) of the combined voting power of all classes\nof capital stock of another corporation and (2) deriving at least\nninety-five percent (95%) of its gross receipts from dividends,\ninterest, royalties, rents, services provided to members of an\naffiliated group (as defined in Section 27-7- 37(2)(d)) to the extent\nof the cost of providing such services.\nPer Miss. Ann. Code §27-13-1(i), in the case of a holding\ncorporation, the value of the capital used, invested or employed\nin this state shall exclude that portion of the book value of the\nholding corporation’s investment in stock or securities of its\nsubsidiary corporation using the ratio between (1) the holding\ncorporation’s investment in stock or securities of its subsidiary\ncorporation and (2) the holding corporation’s total assets. Such\nratio shall then be applied to the total capital stock, surplus,\nundivided profits, and true reserves of the holding corporation in\norder to arrive at the amount of the exclusion. The holding\ncompany exclusion is computed on line 7 of Form 84-110 and a\nschedule of computation must be attached to the return for the\nexclusion.",
          "role": "holding_corporation_franchise_rule_outside_elective_income_scope",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4.pdf",
          "source_sha256": "0f5c7a7d29dbf0ae95ba546c73f8d000246d476f03b928b84d6d5c16b965d7a4",
          "source_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20PTE%20INSTRUCTIONS%2084-100%20-%20Final%20%2001.14.2026.pdf"
        },
        {
          "pinpoint": "35 Miss. Admin. Code 35.III.2.04.100",
          "quote": "Chapter 04 Interest Income\n\n100    Interest received by or credited to the taxpayer constitutes gross income and is fully\n       taxable, unless specifically exempt or excluded by statute. Interest income includes but is\n       not limited to, interest on savings or other bank deposits; interest on coupon bonds; interest\n       on an open account, a promissory note, a mortgage, or a corporate bond or debenture; the\n       interest portion of a condemnation award; usurious interest; interest on legacies; and\n       interest on life insurance proceeds held under an agreement to pay interest thereon.",
          "role": "current_income_categories",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/e17952fdc2bcf0d7430ae0e13beee452609610f45af63027fb280b884197f1b8.pdf",
          "source_sha256": "e17952fdc2bcf0d7430ae0e13beee452609610f45af63027fb280b884197f1b8",
          "source_url": "https://www.sos.ms.gov/adminsearch/ACCode/00000158c.pdf"
        },
        {
          "pinpoint": "35 Miss. Admin. Code 35.III.2.06.100-.103",
          "quote": "Chapter 06 Dividend Income\n\n100    Dividends are included in gross income unless specifically excluded under Miss. Code\n       Ann. Section 27-7-15(4)(i).\n\n101    The term \"dividend\" for the purpose of the Mississippi Income Tax Law means any\n       distribution of property in the ordinary course of business, even though extraordinary in\n       amount, made by a domestic or foreign corporation to its shareholders out of earnings and\n       profit.\n\n102    The earnings and profits of the taxable year shall be computed as of the close of such year,\n       without reduction by reason of any distributions made during the taxable year. Liquidating\n       dividends do not have the status of dividends for Mississippi income tax purposes. Such\n       distributions constitute a return of investment and the gain or loss realized or sustained is\n       one of capital.\n\n103    Dividends must be included in gross income of the shareholder if such dividends have not\n       already borne a tax in Mississippi or another state prior to the receipt of same by such\n       shareholders.",
          "role": "current_dividend_rule",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/e17952fdc2bcf0d7430ae0e13beee452609610f45af63027fb280b884197f1b8.pdf",
          "source_sha256": "e17952fdc2bcf0d7430ae0e13beee452609610f45af63027fb280b884197f1b8",
          "source_url": "https://www.sos.ms.gov/adminsearch/ACCode/00000158c.pdf"
        },
        {
          "pinpoint": "HB 1668 (2023), § 1 amending Miss. Code § 27-7-26(2)",
          "quote": "For calendar\r\nyear 2022, and for each calendar year thereafter, any partnership, S corporation\r\nor similar pass-through entity may elect to be taxed as an electing pass-through\r\nentity and pay the tax imposed under this chapter at the entity level.",
          "role": "enacted_section_anchor",
          "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7.html",
          "source_sha256": "3bcf97f34adddffb6a77bd4fed6a3b6407c73786e1ff002af4887303947231b7",
          "source_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm"
        }
      ],
      "capture_date": "2026-10-06",
      "claim_type": "closest_official_passage_for_official_record_silent",
      "display": null,
      "fetch_event_id": null,
      "pinpoint": "Notice 80-23-002, Filing an Electing Pass-Through Entity Return",
      "public_reason": "The official record does not state this",
      "publish_status": "typed_unknown",
      "quote": "Filing an Electing Pass-Through Entity Return\nAn electing PTE will file the Pass-Through Entity Tax Return, form 84-105, and check the “Electing Pass-Through\nEntity” check box in order to be taxed at the entity level. A copy of the Pass-Through Entity Election Form, form\n84-381, should also be attached to the return.",
      "readiness": "official_record_silent",
      "reason_code": "value_not_stated_in_source",
      "rendered": "badge",
      "snapshot_path": "rigs/content-production/pp-program-2026-10-03/lanes/01-cells/r2.q4.settle.ht-MS/captures/abd380dae7d94e0b569667ff763f9ed075ba84426ef725c2886c4ed768a396f7.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "abd380dae7d94e0b569667ff763f9ed075ba84426ef725c2886c4ed768a396f7",
      "source_url": "https://www.dor.ms.gov/sites/default/files/notices-technical-bulletins/Pass-Through%2520Entity%2520Revised%2520Election%2520Notice%25204-13-23.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.base_tax_locator.alternative_corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-31-406",
          "quote": "15-31-406 . Corporate income tax sections incorporated by reference. The provisions of the following sections of this chapter are incorporated into this part by reference and made a part of this part: (1) that part of 15-31-101 that defines the term \"corporation\" and 15-31-102 , which specifies the classes of organizations whose income may not be taxed; (2) sections 15-31-111 through 15-31-114 , 15-31-117 through 15-31-119 , 15-31-141 , 15-31-142 , 15-31-301 through 15-31-313 , 15-31-501 through 15-31-506 , 15-31-509 , 15-31-511 , 15-31-525 , 15-31-526 , 15-31-531 , 15-31-532 , 15-31-541 , and 15-31-543 , except that the term \"gross income\" must be construed as excluding the net amount of interest income from valid obligations of the United States and except that wherever the words \"tax\", \"corporate income tax\", \"license tax\", \"license fee\", \"corporation excise tax\", or similar words appear, referring to the tax imposed under part 1 of this chapter, there is substituted the words \"alternative corporate income tax\".",
          "role": "incorporated base and deduction sections",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/864a429f2f4f6016d801dc366a065b37148cc772f7f463bf7da2ebb9bf61a587.html",
          "source_sha256": "864a429f2f4f6016d801dc366a065b37148cc772f7f463bf7da2ebb9bf61a587",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0060/0150-0310-0040-0060.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The alternative-tax rate and source rules are in §15-31-403; §15-31-406 incorporates the corporate income and deduction provisions.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. §§ 15-31-403 and -406",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) Except as provided in 15-31-401 , there is hereby imposed upon every corporation for each taxable year an income tax at the rate specified in 15-31-121 and 15-31-122 upon its net income derived from sources within this state for taxable years beginning after December 31, 1970, other than income for any period for which the corporation is subject to taxation under part 1 of this chapter, according to or measured by its net income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/fe13fa84b048b4b46a5c3aa94de61b9717f657a34244f20cab232f7c73863622.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fe13fa84b048b4b46a5c3aa94de61b9717f657a34244f20cab232f7c73863622",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0030/0150-0310-0040-0030.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-31-101(3)",
          "quote": "(3) Except as provided in 15-31-103 or 33-2-705 (4) or as may be otherwise specifically provided, a corporation engaged in business in the state of Montana shall annually pay to the state treasurer a corporate income tax for the privilege of carrying on business in this state the percentage or percentages of its total net income for the preceding tax year at the rate set forth in this chapter. If a corporation has income from business activity that is taxable both within and outside of this state, the corporate income tax must be measured by the net income derived from or attributable to Montana sources as determined under part 3. Except as provided in 15-31-502 and subject to the due date provision in 15-31-111 (2)(b), the tax is due and payable on the 15th day of the 5th month following the close of the tax year of the corporation. However, the tax becomes a lien as provided in this chapter on the last day of the tax year in which the income was earned and is for the privilege of carrying on business in this state for the tax year in which the income was earned.",
          "role": "levy locator",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/9f2f7dca01e86d7ec96a959ac3da2084a91441253ec06633e8b0d3d2927c7324.html",
          "source_sha256": "9f2f7dca01e86d7ec96a959ac3da2084a91441253ec06633e8b0d3d2927c7324",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0010/0150-0310-0010-0010.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate-income levy, income base, deductions, rate, and minimum-tax locators are in the cited sections.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-121",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "15-31-121 . Rate of tax -- minimum tax -- distribution of revenue. (1) Except as provided in subsection (2), the percentage of net income to be paid under 15-31-101 is 6 3/4% of all net income for the tax period. (2) For a taxpayer making a water's-edge election, the percentage of net income to be paid under 15-31-101 is 7% of all taxable net income for the tax period. (3) Each corporation subject to taxation under this part shall pay a minimum tax of not less than $50.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/b37f570adf758b4b6592ded068857a35943b9be80075b470a778579b9da8c94e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b37f570adf758b4b6592ded068857a35943b9be80075b470a778579b9da8c94e",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0210/0150-0310-0010-0210.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The PTET rate and affected-owner Montana-source-income base are located in Mont. Code Ann. § 15-30-3326(1).",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-30-3326(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) Each electing pass-through entity shall, on or before the due date of the pass-through entity's tax return, pay an entity tax. The entity tax is equal to the highest marginal tax rate in effect under 15-30-2103 for the tax year the election is made multiplied by the distributive share of Montana source income calculated under 15-30-3302 for all owners taxed under this chapter. Electing entities may substitute the distributive share of Montana source income allocated to owners who are residents as defined in 15-30-2101 for the distributive share of Montana source income calculated under 15-30-3302 for all resident owners taxed under this chapter for the computation of the tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/64aa04f6793263c3dcb2e2acc437d7a5235e6a35513b3134c668a89377feccd4.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "64aa04f6793263c3dcb2e2acc437d7a5235e6a35513b3134c668a89377feccd4",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.does_not_reach.alternative_corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-31-119(12)",
          "quote": "(12) Notwithstanding any other provision of this section, the net operating loss deduction is not allowed in the case of a regulated investment company or a fund of a regulated investment company, as defined in section 851(a) or 851(b) of the Internal Revenue Code of 1986, as that section may be amended or renumbered.",
          "role": "RIC net-operating-loss limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/a74388c349c5d788bbe2227823385dc3ebcbbf2a4448bf7912a1d9ea60aa0c61.html",
          "source_sha256": "a74388c349c5d788bbe2227823385dc3ebcbbf2a4448bf7912a1d9ea60aa0c61",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0190/0150-0310-0010-0190.html"
        },
        {
          "pinpoint": "Mont. Code Ann. § 15-31-102(1)(j)",
          "quote": "(j) corporations or associations organized for the exclusive purpose of holding title to property, collecting income from the property, and turning over the entire amount of the income, less expenses, to an organization that itself is exempt from the tax imposed by this title;",
          "role": "exempt-organization title-holding limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/1021f7c1ab910012ebfe1a155b3cd02eaa4bf518c4557d6c8a1c777794e3c452.html",
          "source_sha256": "1021f7c1ab910012ebfe1a155b3cd02eaa4bf518c4557d6c8a1c777794e3c452",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0020/0150-0310-0010-0020.html"
        },
        {
          "pinpoint": "Mont. Code Ann. § 15-31-406(2)",
          "quote": "15-31-406 . Corporate income tax sections incorporated by reference. The provisions of the following sections of this chapter are incorporated into this part by reference and made a part of this part: (1) that part of 15-31-101 that defines the term \"corporation\" and 15-31-102 , which specifies the classes of organizations whose income may not be taxed; (2) sections 15-31-111 through 15-31-114 , 15-31-117 through 15-31-119 , 15-31-141 , 15-31-142 , 15-31-301 through 15-31-313 , 15-31-501 through 15-31-506 , 15-31-509 , 15-31-511 , 15-31-525 , 15-31-526 , 15-31-531 , 15-31-532 , 15-31-541 , and 15-31-543 , except that the term \"gross income\" must be construed as excluding the net amount of interest income from valid obligations of the United States and except that wherever the words \"tax\", \"corporate income tax\", \"license tax\", \"license fee\", \"corporation excise tax\", or similar words appear, referring to the tax imposed under part 1 of this chapter, there is substituted the words \"alternative corporate income tax\".",
          "role": "incorporation of §15-31-114",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/864a429f2f4f6016d801dc366a065b37148cc772f7f463bf7da2ebb9bf61a587.html",
          "source_sha256": "864a429f2f4f6016d801dc366a065b37148cc772f7f463bf7da2ebb9bf61a587",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0060/0150-0310-0040-0060.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The RIC deduction excludes dividends attributable to income not taxed when earned and disallows a dividends-received deduction; the NOL deduction is also unavailable.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-114(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) In the case of a regulated investment company or a fund of a regulated investment company, as defined in section 851(a) or 851(g) of the Internal Revenue Code of 1986, 26 U.S.C. 851(a) or 851(g), as that section may be amended or renumbered, there is allowed a deduction for dividends paid, as defined in section 561 of the Internal Revenue Code of 1986, 26 U.S.C. 561, as that section may be amended or renumbered, except that the deduction for dividends is not allowed with respect to dividends attributable to any income that is not subject to tax under this chapter when earned by the regulated investment company. For the purposes of computing the deduction for dividends paid, the provisions of sections 852(b)(7) and 855 of the Internal Revenue Code of 1986, 26 U.S.C. 852(b)(7) and 855, as those sections may be amended or renumbered, apply. A regulated investment company is not allowed a deduction for dividends received as defined in sections 243 through 245 of the Internal Revenue Code of 1986, 26 U.S.C. 243 through 245, as those sections may be amended or renumbered.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/e85bba2472cb6aa74e51a314355ed4ba901e2c6486216841fb774cba51dfe67c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "e85bba2472cb6aa74e51a314355ed4ba901e2c6486216841fb774cba51dfe67c",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0140/0150-0310-0010-0140.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-31-119(12)",
          "quote": "(12) Notwithstanding any other provision of this section, the net operating loss deduction is not allowed in the case of a regulated investment company or a fund of a regulated investment company, as defined in section 851(a) or 851(b) of the Internal Revenue Code of 1986, as that section may be amended or renumbered.",
          "role": "RIC net-operating-loss limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/a74388c349c5d788bbe2227823385dc3ebcbbf2a4448bf7912a1d9ea60aa0c61.html",
          "source_sha256": "a74388c349c5d788bbe2227823385dc3ebcbbf2a4448bf7912a1d9ea60aa0c61",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0190/0150-0310-0010-0190.html"
        },
        {
          "pinpoint": "Mont. Code Ann. § 15-31-102(1)(j)",
          "quote": "(j) corporations or associations organized for the exclusive purpose of holding title to property, collecting income from the property, and turning over the entire amount of the income, less expenses, to an organization that itself is exempt from the tax imposed by this title;",
          "role": "exempt-organization title-holding limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/1021f7c1ab910012ebfe1a155b3cd02eaa4bf518c4557d6c8a1c777794e3c452.html",
          "source_sha256": "1021f7c1ab910012ebfe1a155b3cd02eaa4bf518c4557d6c8a1c777794e3c452",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0020/0150-0310-0010-0020.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The RIC deduction excludes dividends attributable to income not taxed when earned and disallows a dividends-received deduction; the NOL deduction is also unavailable.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-114(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) In the case of a regulated investment company or a fund of a regulated investment company, as defined in section 851(a) or 851(g) of the Internal Revenue Code of 1986, 26 U.S.C. 851(a) or 851(g), as that section may be amended or renumbered, there is allowed a deduction for dividends paid, as defined in section 561 of the Internal Revenue Code of 1986, 26 U.S.C. 561, as that section may be amended or renumbered, except that the deduction for dividends is not allowed with respect to dividends attributable to any income that is not subject to tax under this chapter when earned by the regulated investment company. For the purposes of computing the deduction for dividends paid, the provisions of sections 852(b)(7) and 855 of the Internal Revenue Code of 1986, 26 U.S.C. 852(b)(7) and 855, as those sections may be amended or renumbered, apply. A regulated investment company is not allowed a deduction for dividends received as defined in sections 243 through 245 of the Internal Revenue Code of 1986, 26 U.S.C. 243 through 245, as those sections may be amended or renumbered.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/e85bba2472cb6aa74e51a314355ed4ba901e2c6486216841fb774cba51dfe67c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "e85bba2472cb6aa74e51a314355ed4ba901e2c6486216841fb774cba51dfe67c",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0140/0150-0310-0010-0140.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "MCA section 2101",
          "quote": "15-30-2101 . Definitions. For the purpose of this chapter, unless otherwise required by the context, the following definitions apply: (1) \"Consumer price index\" means the consumer price index, United States city average, for all items, for all urban consumers (CPI-U), using the 1982-84 base of 100, as published by the bureau of labor statistics of the U.S. department of labor. (2) \"Corporation\" or \"C. corporation\" means a corporation, limited liability company, or other entity: (a) that is treated as an association for federal income tax purposes; (b) for which a valid election under section 1362 of the Internal Revenue Code (26 U.S.C. 1362) is not in effect; and (c) that is not a disregarded entity. (3) \"Department\" means the department of revenue. (4) \"Disregarded entity\" means a business entity: (a) that is disregarded as an entity separate from its owner for federal tax purposes, as provided in United States treasury regulations 301.7701-2 or 301.7701-3, 26 CFR 301.7701-2 or 26 CFR 301.7701-3, or as those regulations may be labeled or amended; or (b) that is a qualified subchapter S. subsidiary that is not treated as a separate corporation, as provided in section 1361(b)(3) of the Internal Revenue Code (26 U.S.C. 1361(b)(3)). (5) \"Dividend\" means: (a) any distribution made by a C. corporation out of its earnings and profits to its shareholders or members, whether in cash or in other property or in stock of the corporation, other than stock dividends; and (b) any distribution made by an S. corporation treated as a dividend for federal income tax purposes. (6) \"Federal adjusted gross income\" means adjusted gross income as defined in section 62 of the Internal Revenue Code, 26 U.S.C. 62. (7) \"Federal taxable income\", when referring to an individual, means taxable income as defined and described in section 63 of the Internal Revenue Code, 26 U.S.C. 63, and, when referring to a trust or estate, means taxable income as defined and described in sections 641 through 692 of the Internal Revenue Code, 26 U.S.C. 641 through 692. (8) \"Fiduciary\" means a guardian, trustee, executor, administrator, receiver, conservator, or any person, whether individual or corporate, acting in any fiduciary capacity for any person, trust, or estate. (9) \"Foreign C. corporation\" means a corporation that is not engaged in or doing business in Montana, as provided in 15-31-101 . (10) \"Foreign government\" means any jurisdiction other than the one embraced within the United States, its territories, and its possessions. (11) \"Head of household\" means a head of household as defined and described in section 2(b) of the Internal Revenue Code, 26 U.S.C. 2(b). (12) \"Inflation factor\" means a number determined for each tax year by dividing the consumer price index for June of the previous tax year by the consumer price index for June 2023. (13) \"Information agents\" includes all individuals and entities acting in whatever capacity, including lessees or mortgagors of real or personal property, fiduciaries, brokers, real estate brokers, employers, and all officers and employees of the state or of any municipal corporation or political subdivision of the state, having the control, receipt, custody, disposal, or payment of interest, rent, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income with respect to which any person or fiduciary is taxable under this chapter. (14) \"Internal Revenue Code\" means the Internal Revenue Code of 1986, as amended, or as it may be labeled or further amended. References to specific provisions of the Internal Revenue Code mean those provisions as they may be otherwise labeled or further amended. (15) \"Joint return\" means one return made jointly by a married individual with that individual's spouse. (16) \"Knowingly\" is as defined in 45-2-101 . (17) \"Limited liability company\" means a limited liability company, domestic limited liability company, or a foreign limited liability company as defined in 35-8-102 . (18) \"Limited liability partnership\" means a limited liability partnership as defined in 35-10-102 . (19) \"Lottery winnings\" means income paid either in lump sum or in periodic payments to: (a) a resident taxpayer on a lottery ticket; or (b) a nonresident taxpayer on a lottery ticket purchased in Montana. (20) \"Married individual\" means a married individual as defined and described in section 7703 of the Internal Revenue Code, 26 U.S.C. 7703. (21) (a) \"Montana source income\" means: (i) wages, salary, tips, and other compensation for services performed in the state or while a resident of the state; (ii) gain attributable to the sale or other transfer of tangible property located in the state, sold or otherwise transferred while a resident of the state, or used or held in connection with a trade, business, or occupation carried on in the state; (iii) gain attributable to the sale or other transfer of intangible property received or accrued while a resident of the state; (iv) interest received or accrued while a resident of the state or from an installment sale of real property or tangible commercial or business personal property located in the state; (v) dividends received or accrued while a resident of the state; (vi) net income or loss derived from a trade, business, profession, or occupation carried on in the state or while a resident of the state; (vii) net income or loss derived from farming activities carried on in the state or while a resident of the state; (viii) net rents from real property and tangible personal property located in the state or received or accrued while a resident of the state; (ix) net royalties from real property and from tangible real property to the extent the property is used in the state or the net royalties are received or accrued while a resident of the state. The extent of use in the state is determined by multiplying the royalties by a fraction, the numerator of which is the number of days of physical location of the property in the state during the royalty period in the tax year and the denominator of which is the number of days of physical location of the property everywhere during all royalty periods in the tax year. If the physical location is unknown or unascertainable by the taxpayer, the property is considered used in the state in which it was located at the time the person paying the royalty obtained possession. (x) patent royalties to the extent the person paying them employs the patent in production, fabrication, manufacturing, or other processing in the state, a patented product is produced in the state, or the royalties are received or accrued while a resident of the state; (xi) net copyright royalties to the extent printing or other publication originates in the state or the royalties are received or accrued while a resident of the state; (xii) partnership income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit: (A) derived from a trade, business, occupation, or profession carried on in the state; (B) derived from the sale or other transfer or the rental, lease, or other commercial exploitation of property located in the state; or (C) taken into account while a resident of the state; (xiii) an S. corporation's separately and nonseparately stated income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit: (A) derived from a trade, business, occupation, or profession carried on in the state; (B) derived from the sale or other transfer or the rental, lease, or other commercial exploitation of property located in the state; or (C) taken into account while a resident of the state; (xiv) social security benefits received or accrued while a resident of the state; (xv) taxable individual retirement account distributions, annuities, pensions, and other retirement benefits received while a resident of the state; (xvi) any other income attributable to the state, including but not limited to lottery winnings, state and federal tax refunds, nonemployee compensation, recapture of tax benefits, and capital loss addbacks; and (xvii) in the case of a nonresident who sells the nonresident's interest in a publicly traded partnership doing business in Montana, the gain described in section 751 of the Internal Revenue Code, 26 U.S.C. 751, multiplied by the Montana apportionment factor. If the net gain or loss resulting from the use of the apportionment factor as provided in this subsection (21)(a)(xvii) does not fairly and equitably represent the nonresident taxpayer's business activity interest, then the nonresident taxpayer may petition for, or the department may require with respect to any and all of the partnership interest, the employment of another method to effectuate an equitable allocation or apportionment of the nonresident's income. This subsection (21)(a)(xvii) is intended to preserve the rights and privileges of a nonresident taxpayer and align those rights with taxpayers who are afforded the same rights under 15-1-601 and 15-31-312 . (b) The term does not include: (i) compensation for military service of members of the armed services of the United States who are not Montana residents and who are residing in Montana solely by reason of compliance with military orders and does not include income derived from their personal property located in the state except with respect to personal property used in or arising from a trade or business carried on in Montana; or (ii) interest paid on loans held by out-of-state financial institutions recognized as such in the state of their domicile, secured by mortgages, trust indentures, or other security interests on real or personal property located in the state, if the loan is originated by a lender doing business in Montana and assigned out-of-state and there is no activity conducted by the out-of-state lender in Montana except periodic inspection of the security. (22) \"Montana taxable income\" means federal taxable income as determined for federal income tax purposes and adjusted as provided in 15-30-2120 . (23) \"Nonresident\" means a natural person who is not a resident. (24) \"Paid\" means paid or accrued or paid or incurred, and the terms \"paid or accrued\" and \"paid or incurred\" must be construed according to the method of accounting used to compute federal taxable income. (25) \"Partner\" means a member of a partnership or a manager or member of any other entity, if treated as a partner for federal income tax purposes. (26) \"Partnership\" means a general or limited partnership, limited liability partnership, limited liability company, or other entity, if treated as a partnership for federal income tax purposes. (27) \"Pass-through entity\" means a partnership, an S. corporation, or a disregarded entity. (28) \"Pension and annuity income\" means: (a) systematic payments of a definitely determinable amount from a qualified pension plan, as that term is used in section 401 of the Internal Revenue Code (26 U.S.C. 401), or systematic payments received as the result of contributions made to a qualified pension plan that are paid to the recipient or recipient's beneficiary upon the cessation of employment; (b) payments received as the result of past service and cessation of employment in the uniformed services of the United States; (c) lump-sum distributions from pension or profit-sharing plans to the extent that the distributions are included in federal adjusted gross income; (d) distributions from individual retirement, deferred compensation, and self-employed retirement plans recognized under sections 401 through 408 of the Internal Revenue Code (26 U.S.C. 401 through 408) to the extent that the distributions are not considered to be premature distributions for federal income tax purposes; or (e) amounts received from fully matured, privately purchased annuity contracts after cessation of regular employment. (29) \"Purposely\" is as defined in 45-2-101 . (30) \"Received\" means received or accrued, and the term \"received or accrued\" must be construed according to the method of accounting used to compute federal taxable income. (31) \"Resident\" applies only to natural persons and includes, for the purpose of determining liability to the tax imposed by this chapter with reference to the income of any taxable year, any person domiciled in the state of Montana and any other person who maintains a permanent place of abode within the state even though temporarily absent from the state and who has not established a residence elsewhere. (32) \"S. corporation\" means an incorporated entity for which a valid election under section 1362 of the Internal Revenue Code, 26 U.S.C. 1362, is in effect. (33) \"Stock dividends\" means new stock issued, for surplus or profits capitalized, to shareholders in proportion to their previous holdings. (34) \"Surviving spouse\" means a surviving spouse as defined and described in section 2(a) of the Internal Revenue Code, 26 U.S.C. 2(a). (35) \"Tax year\" means the taxpayer's taxable year for federal income tax purposes. (36) \"Taxpayer\" includes any person, entity, or fiduciary, resident or nonresident, subject to a tax or other obligation imposed by this chapter and unless otherwise specifically provided does not include a C. corporation.",
          "role": "complete PTET search scope",
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          "source_sha256": "fca40caaa4a3b119ec38ba50707f7c048174ff5b4103a4681d5a719228438652",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0210/section_0010/0150-0300-0210-0010.html"
        },
        {
          "pinpoint": "MCA section 3302",
          "quote": "15-30-3302 . Income or license tax involving pass-through entities -- information returns required. (1) Except as otherwise provided: (a) a partnership is not subject to taxes imposed in Title 15, chapter 30 or 31; (b) an S. corporation is not subject to the taxes imposed in Title 15, chapter 30 or 31; and (c) a disregarded entity is not subject to the taxes imposed in Title 15, chapter 30 or 31. (2) Except as otherwise provided, each partner of a partnership described in subsection (1)(a), each shareholder of an S. corporation described in subsection (1)(b), and each partner, shareholder, member, or other owner of an entity described in subsection (1)(c), the first-tier pass-through entity, is subject to the taxes provided in this chapter, if an individual, trust, or estate, and to the taxes provided in Title 15, chapter 31, if a C. corporation. If a partner, shareholder, member, or other owner of an entity described in subsection (1) is itself a pass-through entity, any individual, trust, or estate to which the first-tier pass-through entity's Montana source income is directly or indirectly passed through is subject to the taxes provided in this chapter and any C. corporation to which the first-tier pass-through entity's Montana source income is directly or indirectly passed through is subject to the taxes provided in Title 15, chapter 31. (3) Income realized for federal income tax purposes by a financial institution that has elected to be treated as an S. corporation under subchapter S. of Chapter 1 of the Internal Revenue Code and by its shareholders that is attributable to the financial institution's change from the bad debt reserve method of accounting provided in section 585 of the Internal Revenue Code, 26 U.S.C. 585, is not taxable under Title 15, chapter 30 or 31, to the extent that the aggregate deductions allowed for federal income tax purposes under 26 U.S.C. 585 exceeded the aggregate deductions that the financial institution is allowed under 15-31-114 (1)(b)(i). (4) A publicly traded partnership as defined in section 7704(b) of the Internal Revenue Code, 26 U.S.C. 7704(b), that is treated as a partnership for the purposes of the Internal Revenue Code is exempt from paying tax under Title 15, chapter 30, as long as it is in compliance with 15-30-3313 . (5) (a) Subject to the due date provision in 15-30-2604 (1)(b), a partnership that has Montana source income shall on or before the 15th day of the 3rd month following the close of its annual accounting period file an information return on forms prescribed by the department and a copy of its federal partnership return. The return must include: (i) the name, address, and social security number or federal identification number of each partner; (ii) the partnership's Montana source income; (iii) each partner's distributive share of Montana source income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit; (iv) each partner's distributive share of income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit from all sources; and (v) any other information the department prescribes. (b) Subject to the due date provision in 15-30-2604 (1)(b), an S. corporation that has Montana source income shall on or before the 15th day of the 3rd month following the close of its annual accounting period file an information return on forms prescribed by the department and a copy of its federal S. corporation return. The return must include: (i) the name, address, and social security number or federal identification number of each shareholder; (ii) the S. corporation's Montana source income and each shareholder's pro rata share of separately and nonseparately stated Montana source income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit; (iii) each shareholder's pro rata share of separately and nonseparately stated income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit from all sources; and (iv) any other information the department prescribes. (c) A disregarded entity that has Montana source income shall furnish the information and file the returns the department prescribes. The return must include: (i) the name, address, and social security number or federal identification number of each member or other owner during the tax year; (ii) the entity's Montana source income; and (iii) any other information the department prescribes. (d) (i) Except as provided in subsection (5)(d)(ii), a pass-through entity that fails to file an information return required by this section by the due date, including any extension, must be assessed a late filing penalty of $10 multiplied by the number of the entity's partners, shareholders, members, or other owners at the close of the tax year for each month or fraction of a month, not to exceed 5 months, that the entity fails to file the information return. The penalty may not exceed $2,500 for any one tax period. The department may waive the penalty imposed by this subsection (5)(d)(i) as provided in 15-1-206 . (ii) The penalty imposed under subsection (5)(d)(i) may not be imposed on a pass-through entity that has 10 or fewer partners, shareholders, members, or other owners, each of whom: (A) is an individual, an estate of a deceased individual, or a C. corporation; (B) has filed any required return or other report with the department by the due date, including any extension of time, for the return or report; and (C) has paid all taxes when due. (6) For purposes of this part: (a) a partnership or S. corporation with business activity occurring both within and outside of this state shall calculate its Montana source income pursuant to the allocation and apportionment provisions contained in Title 15, chapter 31, part 3; and (b) a disregarded entity that is not owned by an individual, estate, or trust and that has business activity occurring both within and outside of this state shall calculate its Montana source income pursuant to the allocation and apportionment provisions contained in Title 15, chapter 31, part 3.",
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        },
        {
          "pinpoint": "MCA section 3325",
          "quote": "15-30-3325 . Definitions. As used in 15-30-3326 through 15-30-3328 and this section, unless the context clearly indicates otherwise, the following definitions apply: (1) \"Electing pass-through entity\" means a partnership or an S. corporation that elects to be subject to an entity tax. (2) \"Entity tax\" means a tax that an electing pass-through entity elects to pay under 15-30-3325 through 15-30-3328 and this section. (3) \"Nonresident owner\" means an individual, estate, or trust that is not a resident owner. (4) \"Owner\" means a shareholder of an S. corporation or a partner in a partnership. (5) \"Resident owner\" means an individual, estate, or trust owner that is a resident of the state.",
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          "source_sha256": "b30b2f58b80b1aaf5cde216e519f5a46851c850be48d4d5b947181c7f4d8b92f",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0250/0150-0300-0330-0250.html"
        },
        {
          "pinpoint": "MCA section 3327",
          "quote": "15-30-3327 . Making pass-through entity tax election. (1) The election must be made annually no later than the due date, including extensions, of the pass-through entity's tax return as prescribed by 15-30-3302 . The election for a tax year is irrevocable for the year it is made. (2) The pass-through entity must designate a Montana pass-through entity representative who is authorized to make the election to subject the pass-through entity to the tax provided for in 15-30-3325 through 15-30-3328 . (a) The Montana pass-through entity representative acts on behalf of the pass-through entity for the applicable tax year. (b) With respect to an action required or permitted to be taken by a pass-through entity under 15-30-3325 through 15-30-3328 and a proceeding under 15-1-211 with respect to the action, the Montana pass-through entity representative for the tax year has the sole authority to act on behalf of the pass-through entity, and the pass-through entity's direct owners and indirect owners are bound by those actions. (c) The department may establish reasonable qualifications and procedures for designating a person to be the Montana pass-through entity representative. (3) Nothing in this section prevents a pass-through entity that does not have business activity in the state during the tax year but that does have resident owners from electing to pay the entity tax.",
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          "source_sha256": "260949a42a2666e809134bae83cf853f1a8322c94b6f553a60da0cbf29e8d5ef",
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        },
        {
          "pinpoint": "MCA section 3328",
          "quote": "15-30-3328 . Pass-through entity tax -- refundable credit -- credit for taxes paid to another state. (1) An owner that is not a pass-through entity may claim the distributive share of the owner's entity tax paid by an electing pass-through entity as a refundable credit against the taxes under this chapter. (2) An owner that is an electing pass-through entity shall claim its distributive share of entity tax paid by another pass-through entity as a refundable credit against the taxes under 15-30-3312 , 15-30-3313 , or 15-30-3326 (1). (3) An owner that is not an electing pass-through entity must allocate its distributive share of entity tax paid by another pass-through entity and any amount of estimated tax paid to owners subject to tax under this chapter based on the owner's share of profit and loss. The owner that is not an electing pass-through entity may claim the remainder as an overpayment or refund. (4) Sections 15-30-3325 through 15-30-3328 do not prevent a resident owner from claiming a credit for taxes paid to another state as provided in 15-30-2302 .",
          "role": "complete PTET search scope",
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          "source_sha256": "b8015d10e7bc9b66d208e8b33c3e5571c9a5a71589e5812c5132ef419899b122",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0280/0150-0300-0330-0280.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The complete PTET provisions state no holding-income or holding-entity limit on the universal electing-entity imposition.",
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      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.effective_period.alternative_corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The alternative corporate income tax applies to taxable years beginning after December 31, 1970.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-403(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "for taxable years beginning after December 31, 1970, other than income for any period for which the corporation is subject to taxation under part 1 of this chapter, according to or measured by its net income.",
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      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MT.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate income tax provision states that a corporation engaged in Montana business pays the tax annually.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-101(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "a corporation engaged in business in the state of Montana shall annually pay to the state treasurer a corporate income tax for the privilege of carrying on business in this state the percentage or percentages of its total net income for the preceding tax year at the rate set forth in this chapter.",
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      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-30-3325",
          "quote": "15-30-3325 . Definitions. As used in 15-30-3326 through 15-30-3328 and this section, unless the context clearly indicates otherwise, the following definitions apply: (1) \"Electing pass-through entity\" means a partnership or an S. corporation that elects to be subject to an entity tax. (2) \"Entity tax\" means a tax that an electing pass-through entity elects to pay under 15-30-3325 through 15-30-3328 and this section. (3) \"Nonresident owner\" means an individual, estate, or trust that is not a resident owner. (4) \"Owner\" means a shareholder of an S. corporation or a partner in a partnership. (5) \"Resident owner\" means an individual, estate, or trust owner that is a resident of the state.",
          "role": "complete PTET effective-period search",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/b30b2f58b80b1aaf5cde216e519f5a46851c850be48d4d5b947181c7f4d8b92f.html",
          "source_sha256": "b30b2f58b80b1aaf5cde216e519f5a46851c850be48d4d5b947181c7f4d8b92f",
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        },
        {
          "pinpoint": "Mont. Code Ann. § 15-30-3327",
          "quote": "15-30-3327 . Making pass-through entity tax election. (1) The election must be made annually no later than the due date, including extensions, of the pass-through entity's tax return as prescribed by 15-30-3302 . The election for a tax year is irrevocable for the year it is made. (2) The pass-through entity must designate a Montana pass-through entity representative who is authorized to make the election to subject the pass-through entity to the tax provided for in 15-30-3325 through 15-30-3328 . (a) The Montana pass-through entity representative acts on behalf of the pass-through entity for the applicable tax year. (b) With respect to an action required or permitted to be taken by a pass-through entity under 15-30-3325 through 15-30-3328 and a proceeding under 15-1-211 with respect to the action, the Montana pass-through entity representative for the tax year has the sole authority to act on behalf of the pass-through entity, and the pass-through entity's direct owners and indirect owners are bound by those actions. (c) The department may establish reasonable qualifications and procedures for designating a person to be the Montana pass-through entity representative. (3) Nothing in this section prevents a pass-through entity that does not have business activity in the state during the tax year but that does have resident owners from electing to pay the entity tax.",
          "role": "complete PTET effective-period search",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/260949a42a2666e809134bae83cf853f1a8322c94b6f553a60da0cbf29e8d5ef.html",
          "source_sha256": "260949a42a2666e809134bae83cf853f1a8322c94b6f553a60da0cbf29e8d5ef",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0270/0150-0300-0330-0270.html"
        },
        {
          "pinpoint": "Mont. Code Ann. § 15-30-3328",
          "quote": "15-30-3328 . Pass-through entity tax -- refundable credit -- credit for taxes paid to another state. (1) An owner that is not a pass-through entity may claim the distributive share of the owner's entity tax paid by an electing pass-through entity as a refundable credit against the taxes under this chapter. (2) An owner that is an electing pass-through entity shall claim its distributive share of entity tax paid by another pass-through entity as a refundable credit against the taxes under 15-30-3312 , 15-30-3313 , or 15-30-3326 (1). (3) An owner that is not an electing pass-through entity must allocate its distributive share of entity tax paid by another pass-through entity and any amount of estimated tax paid to owners subject to tax under this chapter based on the owner's share of profit and loss. The owner that is not an electing pass-through entity may claim the remainder as an overpayment or refund. (4) Sections 15-30-3325 through 15-30-3328 do not prevent a resident owner from claiming a credit for taxes paid to another state as provided in 15-30-2302 .",
          "role": "complete PTET effective-period search",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The complete four-section PTET subpart states annual operation but no effective or sunset date in its operative text.",
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      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MT.llc.filing_rule.alternative_corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-31-406(2)",
          "quote": "15-31-406 . Corporate income tax sections incorporated by reference. The provisions of the following sections of this chapter are incorporated into this part by reference and made a part of this part: (1) that part of 15-31-101 that defines the term \"corporation\" and 15-31-102 , which specifies the classes of organizations whose income may not be taxed; (2) sections 15-31-111 through 15-31-114 , 15-31-117 through 15-31-119 , 15-31-141 , 15-31-142 , 15-31-301 through 15-31-313 , 15-31-501 through 15-31-506 , 15-31-509 , 15-31-511 , 15-31-525 , 15-31-526 , 15-31-531 , 15-31-532 , 15-31-541 , and 15-31-543 , except that the term \"gross income\" must be construed as excluding the net amount of interest income from valid obligations of the United States and except that wherever the words \"tax\", \"corporate income tax\", \"license tax\", \"license fee\", \"corporation excise tax\", or similar words appear, referring to the tax imposed under part 1 of this chapter, there is substituted the words \"alternative corporate income tax\".",
          "role": "incorporation of filing section",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/864a429f2f4f6016d801dc366a065b37148cc772f7f463bf7da2ebb9bf61a587.html",
          "source_sha256": "864a429f2f4f6016d801dc366a065b37148cc772f7f463bf7da2ebb9bf61a587",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0060/0150-0310-0040-0060.html"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A corporation files an accurate net-income return for each tax period under the stated calendar- or fiscal-year due-date rule.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-111(1)-(2)",
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      "quote": "(1) A corporation subject to the corporate income tax imposed under this chapter shall for each tax period file an accurate return of its net income for the tax period in the manner and form prescribed by the department. The return must contain all of the information that is appropriate and in the opinion of the department necessary to determine the correctness of the net income disclosed by the return and to carry out the provisions of this chapter. The return must be signed by the president, the vice president, the treasurer, the assistant treasurer, or the chief accounting officer. […] (2) (a) Except as provided in subsection (2)(b), if the corporation is reporting on a calendar year basis, the return must be filed with the department on or before May 15 following the close of the calendar year. If the corporation is reporting on a fiscal year basis, the return must be filed with the department on or before the 15th day of the 5th month following the close of its fiscal year.",
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    "holding_tax:pp-holding-entity-tax#MT.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A corporation files an accurate net-income return for each tax period under the stated calendar- or fiscal-year due-date rule.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-111(1)-(2)",
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      "quote": "(1) A corporation subject to the corporate income tax imposed under this chapter shall for each tax period file an accurate return of its net income for the tax period in the manner and form prescribed by the department. The return must contain all of the information that is appropriate and in the opinion of the department necessary to determine the correctness of the net income disclosed by the return and to carry out the provisions of this chapter. The return must be signed by the president, the vice president, the treasurer, the assistant treasurer, or the chief accounting officer. […] (2) (a) Except as provided in subsection (2)(b), if the corporation is reporting on a calendar year basis, the return must be filed with the department on or before May 15 following the close of the calendar year. If the corporation is reporting on a fiscal year basis, the return must be filed with the department on or before the 15th day of the 5th month following the close of its fiscal year.",
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    "holding_tax:pp-holding-entity-tax#MT.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The election is annual, irrevocable for the year, and due by the extended return deadline; the entity designates an authorized Montana representative.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-30-3327(1)-(2)",
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      "quote": "(1) The election must be made annually no later than the due date, including extensions, of the pass-through entity's tax return as prescribed by 15-30-3302 . The election for a tax year is irrevocable for the year it is made.",
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      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0270/0150-0300-0330-0270.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#MT.llc.tax_regime.alternative_corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-31-101(1)",
          "quote": "(1) The term \"corporation\" includes an association, joint-stock company, common-law trust or business trust that does business in an organized capacity, all other corporations whether created, organized, or existing under and pursuant to the laws, agreements, or declarations of trust of any state, country, or the United States, and any limited liability company, limited liability partnership, partnership, or other entity that is treated as an association for federal income tax purposes and that is not a disregarded entity.",
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        },
        {
          "pinpoint": "Mont. Code Ann. § 15-31-401",
          "quote": "15-31-401 . Application of corporate income tax and alternative corporate income tax. (1) It is the intent of the legislature that the corporate income tax must be applied to all corporations subject to taxation under part 1 of this chapter. Except as provided in subsection (2), the alternative corporate income tax provided by this part must be applied to corporations that are not taxable under part 1 of this chapter but are taxable under an income tax. (2) During its first 5 taxable years of activity in Montana, the net income earned from research and development activities by a research and development firm as described in 15-31-103 is not subject to either the corporate income tax provided in part 1 of this chapter or to the alternative corporate income tax provided in this part.",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The alternative corporate income tax reaches every corporation outside part 1 that is taxable under an income tax and has Montana-source net income.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-403(1)",
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      "publish_status": "publish_ready",
      "quote": "(1) Except as provided in 15-31-401 , there is hereby imposed upon every corporation for each taxable year an income tax at the rate specified in 15-31-121 and 15-31-122 upon its net income derived from sources within this state for taxable years beginning after December 31, 1970, other than income for any period for which the corporation is subject to taxation under part 1 of this chapter, according to or measured by its net income.",
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    "holding_tax:pp-holding-entity-tax#MT.llc.tax_regime.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-31-101(1)",
          "quote": "(1) The term \"corporation\" includes an association, joint-stock company, common-law trust or business trust that does business in an organized capacity, all other corporations whether created, organized, or existing under and pursuant to the laws, agreements, or declarations of trust of any state, country, or the United States, and any limited liability company, limited liability partnership, partnership, or other entity that is treated as an association for federal income tax purposes and that is not a disregarded entity.",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A federally corporation-classified LLC is a corporation under Montana law and pays corporate income tax annually when engaged in business in Montana.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-101(3)",
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      "quote": "(3) Except as provided in 15-31-103 or 33-2-705 (4) or as may be otherwise specifically provided, a corporation engaged in business in the state of Montana shall annually pay to the state treasurer a corporate income tax for the privilege of carrying on business in this state the percentage or percentages of its total net income for the preceding tax year at the rate set forth in this chapter. If a corporation has income from business activity that is taxable both within and outside of this state, the corporate income tax must be measured by the net income derived from or attributable to Montana sources as determined under part 3. Except as provided in 15-31-502 and subject to the due date provision in 15-31-111 (2)(b), the tax is due and payable on the 15th day of the 5th month following the close of the tax year of the corporation. However, the tax becomes a lien as provided in this chapter on the last day of the tax year in which the income was earned and is for the privilege of carrying on business in this state for the tax year in which the income was earned.",
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    "holding_tax:pp-holding-entity-tax#MT.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-30-3325(1)-(2)",
          "quote": "15-30-3325 . Definitions. As used in 15-30-3326 through 15-30-3328 and this section, unless the context clearly indicates otherwise, the following definitions apply: (1) \"Electing pass-through entity\" means a partnership or an S. corporation that elects to be subject to an entity tax. (2) \"Entity tax\" means a tax that an electing pass-through entity elects to pay under 15-30-3325 through 15-30-3328 and this section. (3) \"Nonresident owner\" means an individual, estate, or trust that is not a resident owner. (4) \"Owner\" means a shareholder of an S. corporation or a partner in a partnership. (5) \"Resident owner\" means an individual, estate, or trust owner that is a resident of the state.",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Each electing partnership or S corporation pays Montana entity tax on the stated affected-owner Montana-source-income base.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-30-3326(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) Each electing pass-through entity shall, on or before the due date of the pass-through entity's tax return, pay an entity tax. The entity tax is equal to the highest marginal tax rate in effect under 15-30-2103 for the tax year the election is made multiplied by the distributive share of Montana source income calculated under 15-30-3302 for all owners taxed under this chapter. Electing entities may substitute the distributive share of Montana source income allocated to owners who are residents as defined in 15-30-2101 for the distributive share of Montana source income calculated under 15-30-3302 for all resident owners taxed under this chapter for the computation of the tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/64aa04f6793263c3dcb2e2acc437d7a5235e6a35513b3134c668a89377feccd4.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "64aa04f6793263c3dcb2e2acc437d7a5235e6a35513b3134c668a89377feccd4",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.treatment.alternative_corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-31-406(2)",
          "quote": "15-31-406 . Corporate income tax sections incorporated by reference. The provisions of the following sections of this chapter are incorporated into this part by reference and made a part of this part: (1) that part of 15-31-101 that defines the term \"corporation\" and 15-31-102 , which specifies the classes of organizations whose income may not be taxed; (2) sections 15-31-111 through 15-31-114 , 15-31-117 through 15-31-119 , 15-31-141 , 15-31-142 , 15-31-301 through 15-31-313 , 15-31-501 through 15-31-506 , 15-31-509 , 15-31-511 , 15-31-525 , 15-31-526 , 15-31-531 , 15-31-532 , 15-31-541 , and 15-31-543 , except that the term \"gross income\" must be construed as excluding the net amount of interest income from valid obligations of the United States and except that wherever the words \"tax\", \"corporate income tax\", \"license tax\", \"license fee\", \"corporation excise tax\", or similar words appear, referring to the tax imposed under part 1 of this chapter, there is substituted the words \"alternative corporate income tax\".",
          "role": "incorporation of §15-31-114",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/864a429f2f4f6016d801dc366a065b37148cc772f7f463bf7da2ebb9bf61a587.html",
          "source_sha256": "864a429f2f4f6016d801dc366a065b37148cc772f7f463bf7da2ebb9bf61a587",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0060/0150-0310-0040-0060.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A qualifying regulated investment company remains within the corporate regime but receives the stated dividends-paid deduction with express exclusions.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-114(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) In the case of a regulated investment company or a fund of a regulated investment company, as defined in section 851(a) or 851(g) of the Internal Revenue Code of 1986, 26 U.S.C. 851(a) or 851(g), as that section may be amended or renumbered, there is allowed a deduction for dividends paid, as defined in section 561 of the Internal Revenue Code of 1986, 26 U.S.C. 561, as that section may be amended or renumbered, except that the deduction for dividends is not allowed with respect to dividends attributable to any income that is not subject to tax under this chapter when earned by the regulated investment company. For the purposes of computing the deduction for dividends paid, the provisions of sections 852(b)(7) and 855 of the Internal Revenue Code of 1986, 26 U.S.C. 852(b)(7) and 855, as those sections may be amended or renumbered, apply. A regulated investment company is not allowed a deduction for dividends received as defined in sections 243 through 245 of the Internal Revenue Code of 1986, 26 U.S.C. 243 through 245, as those sections may be amended or renumbered.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/e85bba2472cb6aa74e51a314355ed4ba901e2c6486216841fb774cba51dfe67c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "e85bba2472cb6aa74e51a314355ed4ba901e2c6486216841fb774cba51dfe67c",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0140/0150-0310-0010-0140.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A qualifying regulated investment company remains within the corporate regime but receives the stated dividends-paid deduction with express exclusions.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-31-114(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) In the case of a regulated investment company or a fund of a regulated investment company, as defined in section 851(a) or 851(g) of the Internal Revenue Code of 1986, 26 U.S.C. 851(a) or 851(g), as that section may be amended or renumbered, there is allowed a deduction for dividends paid, as defined in section 561 of the Internal Revenue Code of 1986, 26 U.S.C. 561, as that section may be amended or renumbered, except that the deduction for dividends is not allowed with respect to dividends attributable to any income that is not subject to tax under this chapter when earned by the regulated investment company. For the purposes of computing the deduction for dividends paid, the provisions of sections 852(b)(7) and 855 of the Internal Revenue Code of 1986, 26 U.S.C. 852(b)(7) and 855, as those sections may be amended or renumbered, apply. A regulated investment company is not allowed a deduction for dividends received as defined in sections 243 through 245 of the Internal Revenue Code of 1986, 26 U.S.C. 243 through 245, as those sections may be amended or renumbered.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/e85bba2472cb6aa74e51a314355ed4ba901e2c6486216841fb774cba51dfe67c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "e85bba2472cb6aa74e51a314355ed4ba901e2c6486216841fb774cba51dfe67c",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0140/0150-0310-0010-0140.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#MT.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Mont. Code Ann. § 15-30-3302",
          "quote": "15-30-3302 . Income or license tax involving pass-through entities -- information returns required. (1) Except as otherwise provided: (a) a partnership is not subject to taxes imposed in Title 15, chapter 30 or 31; (b) an S. corporation is not subject to the taxes imposed in Title 15, chapter 30 or 31; and (c) a disregarded entity is not subject to the taxes imposed in Title 15, chapter 30 or 31. (2) Except as otherwise provided, each partner of a partnership described in subsection (1)(a), each shareholder of an S. corporation described in subsection (1)(b), and each partner, shareholder, member, or other owner of an entity described in subsection (1)(c), the first-tier pass-through entity, is subject to the taxes provided in this chapter, if an individual, trust, or estate, and to the taxes provided in Title 15, chapter 31, if a C. corporation. If a partner, shareholder, member, or other owner of an entity described in subsection (1) is itself a pass-through entity, any individual, trust, or estate to which the first-tier pass-through entity's Montana source income is directly or indirectly passed through is subject to the taxes provided in this chapter and any C. corporation to which the first-tier pass-through entity's Montana source income is directly or indirectly passed through is subject to the taxes provided in Title 15, chapter 31. (3) Income realized for federal income tax purposes by a financial institution that has elected to be treated as an S. corporation under subchapter S. of Chapter 1 of the Internal Revenue Code and by its shareholders that is attributable to the financial institution's change from the bad debt reserve method of accounting provided in section 585 of the Internal Revenue Code, 26 U.S.C. 585, is not taxable under Title 15, chapter 30 or 31, to the extent that the aggregate deductions allowed for federal income tax purposes under 26 U.S.C. 585 exceeded the aggregate deductions that the financial institution is allowed under 15-31-114 (1)(b)(i). (4) A publicly traded partnership as defined in section 7704(b) of the Internal Revenue Code, 26 U.S.C. 7704(b), that is treated as a partnership for the purposes of the Internal Revenue Code is exempt from paying tax under Title 15, chapter 30, as long as it is in compliance with 15-30-3313 . (5) (a) Subject to the due date provision in 15-30-2604 (1)(b), a partnership that has Montana source income shall on or before the 15th day of the 3rd month following the close of its annual accounting period file an information return on forms prescribed by the department and a copy of its federal partnership return. The return must include: (i) the name, address, and social security number or federal identification number of each partner; (ii) the partnership's Montana source income; (iii) each partner's distributive share of Montana source income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit; (iv) each partner's distributive share of income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit from all sources; and (v) any other information the department prescribes. (b) Subject to the due date provision in 15-30-2604 (1)(b), an S. corporation that has Montana source income shall on or before the 15th day of the 3rd month following the close of its annual accounting period file an information return on forms prescribed by the department and a copy of its federal S. corporation return. The return must include: (i) the name, address, and social security number or federal identification number of each shareholder; (ii) the S. corporation's Montana source income and each shareholder's pro rata share of separately and nonseparately stated Montana source income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit; (iii) each shareholder's pro rata share of separately and nonseparately stated income, gain, loss, deduction, or credit or item of income, gain, loss, deduction, or credit from all sources; and (iv) any other information the department prescribes. (c) A disregarded entity that has Montana source income shall furnish the information and file the returns the department prescribes. The return must include: (i) the name, address, and social security number or federal identification number of each member or other owner during the tax year; (ii) the entity's Montana source income; and (iii) any other information the department prescribes. (d) (i) Except as provided in subsection (5)(d)(ii), a pass-through entity that fails to file an information return required by this section by the due date, including any extension, must be assessed a late filing penalty of $10 multiplied by the number of the entity's partners, shareholders, members, or other owners at the close of the tax year for each month or fraction of a month, not to exceed 5 months, that the entity fails to file the information return. The penalty may not exceed $2,500 for any one tax period. The department may waive the penalty imposed by this subsection (5)(d)(i) as provided in 15-1-206 . (ii) The penalty imposed under subsection (5)(d)(i) may not be imposed on a pass-through entity that has 10 or fewer partners, shareholders, members, or other owners, each of whom: (A) is an individual, an estate of a deceased individual, or a C. corporation; (B) has filed any required return or other report with the department by the due date, including any extension of time, for the return or report; and (C) has paid all taxes when due. (6) For purposes of this part: (a) a partnership or S. corporation with business activity occurring both within and outside of this state shall calculate its Montana source income pursuant to the allocation and apportionment provisions contained in Title 15, chapter 31, part 3; and (b) a disregarded entity that is not owned by an individual, estate, or trust and that has business activity occurring both within and outside of this state shall calculate its Montana source income pursuant to the allocation and apportionment provisions contained in Title 15, chapter 31, part 3.",
          "role": "pass-through base and filing rules",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/37a45c9e5c71b2b8c770cc3d0b46d09bde79581cb0183f0a7f6b65849911bd86.html",
          "source_sha256": "37a45c9e5c71b2b8c770cc3d0b46d09bde79581cb0183f0a7f6b65849911bd86",
          "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0020/0150-0300-0330-0020.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Every electing pass-through entity pays the entity tax under the universal imposition; complete search found no holding/passive exception.",
      "fetch_event_id": null,
      "pinpoint": "Mont. Code Ann. § 15-30-3326(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) Each electing pass-through entity shall, on or before the due date of the pass-through entity's tax return, pay an entity tax. The entity tax is equal to the highest marginal tax rate in effect under 15-30-2103 for the tax year the election is made multiplied by the distributive share of Montana source income calculated under 15-30-3302 for all owners taxed under this chapter. Electing entities may substitute the distributive share of Montana source income allocated to owners who are residents as defined in 15-30-2101 for the distributive share of Montana source income calculated under 15-30-3302 for all resident owners taxed under this chapter for the computation of the tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/MT/snapshots/c50/MT/64aa04f6793263c3dcb2e2acc437d7a5235e6a35513b3134c668a89377feccd4.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "64aa04f6793263c3dcb2e2acc437d7a5235e6a35513b3134c668a89377feccd4",
      "source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": [
        {
          "evidence_role": "base_adjustment",
          "pinpoint": "N.C. Gen. Stat. § 105-130.5(b)(3a)-(3b)",
          "quote": "Dividends treated as received from sources outside the United States as determined under section 862 of the Code, net of related expenses, to the extent included in federal taxable income. Notwithstanding the proviso in subdivision (c)(3) of this section, the netting of related expenses shall be calculated in accordance with subdivision (c)(3) of this section. (3b) Any amount included in federal taxable income under section 78, 951, 951A, or 965 of the Code, net of related expenses.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-130.5.html/NC/bfa6a001c806b6b53af5a28d9048688f8042bcffb07176db0c5a233acba06596.html",
          "source_sha256": "bfa6a001c806b6b53af5a28d9048688f8042bcffb07176db0c5a233acba06596",
          "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.5.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Imposition and rate: § 105-130.3; State net-income adjustments: § 105-130.5.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-130.3",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax is imposed on the State net income of every C Corporation doing business in this State. An S Corporation is not subject to the tax levied in this section. The tax is a percentage of the taxpayer's State net income computed as follows: Taxable Years Beginning Tax In 2025 2.25% In 2026 2% In 2028 1% After 2029 0%.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-130.3-accepted.html/590cd4b90fb4d9aebcceb4aebeef008b20afcec3e6ec9cda80addfe82cdfdefe.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "590cd4b90fb4d9aebcceb4aebeef008b20afcec3e6ec9cda80addfe82cdfdefe",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.3.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "evidence_role": "partnership_base",
          "pinpoint": "N.C. Gen. Stat. § 105-154.1(b)",
          "quote": "Taxable Income of Taxed Partnership. - A tax is imposed for the taxable period on the North Carolina taxable income of a taxed partnership. The tax shall be levied, collected, and paid annually. The tax is imposed on the North Carolina taxable income at the rate levied in G.S. 105-153.7. The North Carolina taxable income of a taxed partnership is determined as follows: (1) The North Carolina taxable income of a taxed partnership with respect to such taxable period shall be equal to the sum of the following for partners defined under G.S. 105-154.1(a)(1) through G.S. 105-154.1(a)(4): a. Each partner's distributive share of the taxed partnership's income or loss, subject to the adjustments provided in G.S. 105-153.5 and G.S. 105-153.6, attributable to the State. b. (Repealed effective for taxable years beginning on or after January 1, 2023) Each resident partner's distributive share of the taxed partnership's income or loss, subject to the adjustments provided in G.S. 105-153.5 and G.S. 105-153.6, not attributable to the State with respect to such taxable period. (2) Separately stated items of deduction are not included when calculating each partner's distributive share of the taxed partnership's taxable income. For purposes of this subdivision, separately stated items are those items described in section 702 of the Code and the regulations adopted under it. (3) The adjustments required by G.S. 105-153.5(c3) are not included in the calculation of the taxed partnership's taxable income.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-154.1.html/NC/757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b.html",
          "source_sha256": "757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b",
          "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-154.1.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Taxed-S-corporation base: § 105-131.1A(b); taxed-partnership base: § 105-154.1(b); rate: § 105-153.7.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-131.1A(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Taxable Income of Taxed S Corporation. - A tax is imposed for the taxable period on the North Carolina taxable income of a taxed S Corporation. The tax shall be levied, collected, and paid annually. The tax is imposed on the North Carolina taxable income at the rate levied in G.S. 105-153.7. The North Carolina taxable income of a taxed S Corporation is determined as follows: (1) The North Carolina taxable income of a taxed S Corporation with respect to such taxable period shall be equal to the sum of the following: a. Each shareholder's pro rata share of the taxed S Corporation's income or loss, subject to the adjustments provided in G.S. 105-153.5 and G.S. 105-153.6, attributable to the State. b. (Repealed effective for taxable years beginning on or after January 1, 2023) Each resident shareholder's pro rata share of the taxed S Corporation's income or loss, subject to the adjustments provided in G.S. 105-153.5 and G.S. 105-153.6, not attributable to the State with respect to such taxable period. (2) Separately stated items of deduction are not included when calculating each shareholder's pro rata share of the taxed S Corporation's taxable income. For purposes of this subdivision, separately stated items are those items described in section 1366 of the Code and the regulations under it. (3) The adjustments required by G.S. 105-153.5(c3) are not included in the calculation of the taxed S Corporation's taxable income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-131.1A.html/7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.base_tax_locator.franchise_tax": {
      "additional_sources": [
        {
          "evidence_role": "general_franchise_base",
          "pinpoint": "N.C. Gen. Stat. § 105-122(a)-(b)",
          "quote": "Tax Imposed. - An annual franchise or privilege tax is imposed on a corporation doing business in this State for the privilege of doing business in this State and for the continuance of articles of incorporation or domestication of each corporation in this State. A corporation subject to the tax must file a return under affirmation with the Secretary at the place and in the manner prescribed by the Secretary. The return must be signed by the president, vice-president, treasurer, or chief financial officer of the corporation. The return is due on or before the fifteenth day of the fourth month following the end of the corporation's income year.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-122.html/b0248e51a17037dc819ff2ccff44508d452670511a045ac5ca2ac4d286e0e846.html",
          "source_sha256": "b0248e51a17037dc819ff2ccff44508d452670511a045ac5ca2ac4d286e0e846",
          "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-122.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Holding-company base and rate: § 105-120.2(a)-(b); general corporate net-worth base: § 105-122(b).",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-120.2(a)-(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every corporation, domestic and foreign, incorporated or, by an act, domesticated under the laws of this State or doing business in this State that, at the close of its taxable year, is a holding company as defined in subsection (c) of this section, shall, pursuant to the provisions of G.S. 105-122, do all of the following: (1) File a return. (2) Determine the total amount of its net worth. (3) Apportion its net worth to this State. […] (Effective for taxable years beginning on or after January 1, 2025) Tax Rate. - Every corporation taxed under this section shall annually pay to the Secretary of Revenue, at the time the return is due, a franchise or privilege tax at the rate of one dollar and fifty cents ($1.50) per one thousand dollars ($1,000) of its tax base with a maximum of five hundred dollars ($500.00) for the first one million dollars ($1,000,000) of the corporation's tax base as determined under subsection (a) of this section, but in no case shall the tax be more than one hundred fifty thousand dollars ($150,000) nor less than two hundred dollars ($200.00).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-120.2.html/NC/8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Expenses related to untaxed income remain nondeductible; for untaxed dividends, the expense adjustment is capped at 15% of the dividends.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-130.5(c)(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "No deduction is allowed for any direct or indirect expenses related to income not taxed under this Part; provided, no adjustment shall be made under this subsection for adjustments addressed in G.S. 105-130.5(a) and (b). For dividends received that are not taxed under this Part, the adjustment for expenses may not exceed an amount equal to fifteen percent (15%) of the dividends.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-130.5.html/NC/bfa6a001c806b6b53af5a28d9048688f8042bcffb07176db0c5a233acba06596.html",
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      "source_class": "S1",
      "source_sha256": "bfa6a001c806b6b53af5a28d9048688f8042bcffb07176db0c5a233acba06596",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.5.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A publicly traded partnership described in Code § 7704(c), or a partnership with an unlisted partner type, cannot make the election.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-154.1(a), taxable years beginning on or after January 1, 2023",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(Effective for taxable years beginning on or after January 1, 2023) Taxed Partnership Election. - A partnership may elect, on its timely filed return required under G.S. 105-154(c), to have the tax under this Article imposed on the partnership for any taxable period covered by the return. A partnership may not make or revoke the election after the return is filed. This election cannot be made by a publicly traded partnership that is described in section 7704(c) of the Code or by a partnership that has at any time during the taxable year a partner who is not one of the following: (1) An individual. (2) An estate. (3) Any of the following: a. A trust described in section 1361(c)(2) of the Code. b. A trust if such trust does not have as a beneficiary any person other than an individual, an estate, a trust, or an organization described in section 1361(c)(6) of the Code. (4) An organization described in section 1361(c)(6) of the Code. (5) A partnership, including an entity that is classified as a partnership for federal income tax purposes, or an entity that is classified as a corporation for federal income tax purposes.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-154.1.html/NC/757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-154.1.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.does_not_reach.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The general § 105-122 franchise tax does not apply to a business taxed under the holding-company provision, § 105-120.2.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-120.2(e)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Counties, cities and towns shall not levy a franchise tax on corporations taxed under this section. The tax imposed under the provisions of G.S. 105-122 shall not apply to businesses taxed under the provisions of this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-120.2.html/NC/8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Section 105-130.3 lists 2.25% for 2025, 2% for 2026, 1% for 2028, and 0% after 2029.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-130.3",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax is imposed on the State net income of every C Corporation doing business in this State. An S Corporation is not subject to the tax levied in this section. The tax is a percentage of the taxpayer's State net income computed as follows: Taxable Years Beginning Tax In 2025 2.25% In 2026 2% In 2028 1% After 2029 0%.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-130.3-accepted.html/590cd4b90fb4d9aebcceb4aebeef008b20afcec3e6ec9cda80addfe82cdfdefe.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "590cd4b90fb4d9aebcceb4aebeef008b20afcec3e6ec9cda80addfe82cdfdefe",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.3.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "evidence_role": "current_partnership_period",
          "pinpoint": "N.C. Gen. Stat. § 105-154.1(a)",
          "quote": "(Effective for taxable years beginning on or after January 1, 2023) Taxed Partnership Election. - A partnership may elect, on its timely filed return required under G.S. 105-154(c), to have the tax under this Article imposed on the partnership for any taxable period covered by the return. A partnership may not make or revoke the election after the return is filed. This election cannot be made by a publicly traded partnership that is described in section 7704(c) of the Code or by a partnership that has at any time during the taxable year a partner who is not one of the following: (1) An individual. (2) An estate. (3) Any of the following: a. A trust described in section 1361(c)(2) of the Code. b. A trust if such trust does not have as a beneficiary any person other than an individual, an estate, a trust, or an organization described in section 1361(c)(6) of the Code. (4) An organization described in section 1361(c)(6) of the Code. (5) A partnership, including an entity that is classified as a partnership for federal income tax purposes, or an entity that is classified as a corporation for federal income tax purposes.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-154.1.html/NC/757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b.html",
          "source_sha256": "757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b",
          "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-154.1.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The current taxed-S-corporation and taxed-partnership election language applies to taxable years beginning on or after January 1, 2023.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-131.1A(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(Effective for taxable years beginning on or after January 1, 2023) Taxed S Corporation Election. - An S Corporation may elect, on its timely filed return required under G.S. 105-131.7, to have the tax under this Article imposed on the S Corporation for any taxable period covered by the return. An S Corporation may not make or revoke the election after the return is filed.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-131.1A.html/7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.effective_period.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-120.2(b), taxable years beginning on or after January 1, 2025",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(Effective for taxable years beginning on or after January 1, 2025) Tax Rate. - Every corporation taxed under this section shall annually pay to the Secretary of Revenue, at the time the return is due, a franchise or privilege tax at the rate of one dollar and fifty cents ($1.50) per one thousand dollars ($1,000) of its tax base with a maximum of five hundred dollars ($500.00) for the first one million dollars ($1,000,000) of the corporation's tax base as determined under subsection (a) of this section, but in no case shall the tax be more than one hundred fifty thousand dollars ($150,000) nor less than two hundred dollars ($200.00).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-120.2.html/NC/8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A corporation generally files its return by the fifteenth day of the fourth month after its income year closes.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-130.17(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as otherwise provided in this section, the return of a corporation shall be filed on or before the fifteenth day of the fourth month following the close of its income year. An income year ending on any day other than the last day of the month shall be deemed to end on the last day of the calendar month ending nearest to the last day of a taxpayer's actual income year.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-130.17.html/NC/2c8a6544f6a23759b68b6a4e29584d7b36a6b4d6d04f3ccc8a64e9a63bc3a62a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2c8a6544f6a23759b68b6a4e29584d7b36a6b4d6d04f3ccc8a64e9a63bc3a62a",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.17.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "evidence_role": "partnership_election",
          "pinpoint": "N.C. Gen. Stat. § 105-154.1(a)",
          "quote": "(Effective for taxable years beginning on or after January 1, 2023) Taxed Partnership Election. - A partnership may elect, on its timely filed return required under G.S. 105-154(c), to have the tax under this Article imposed on the partnership for any taxable period covered by the return. A partnership may not make or revoke the election after the return is filed. This election cannot be made by a publicly traded partnership that is described in section 7704(c) of the Code or by a partnership that has at any time during the taxable year a partner who is not one of the following: (1) An individual. (2) An estate. (3) Any of the following: a. A trust described in section 1361(c)(2) of the Code. b. A trust if such trust does not have as a beneficiary any person other than an individual, an estate, a trust, or an organization described in section 1361(c)(6) of the Code. (4) An organization described in section 1361(c)(6) of the Code. (5) A partnership, including an entity that is classified as a partnership for federal income tax purposes, or an entity that is classified as a corporation for federal income tax purposes.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-154.1.html/NC/757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b.html",
          "source_sha256": "757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b",
          "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-154.1.html"
        },
        {
          "evidence_role": "partnership_return",
          "pinpoint": "N.C. Gen. Stat. § 105-154(c)",
          "quote": "Information Returns of Partnerships. - A partnership doing business in this State and required to file a return under the Code shall file an information return with the Secretary. A partnership that the Secretary believes to be doing business in this State and to be required to file a return under the Code shall file an information return when requested to do so by the Secretary. The information return shall contain all information required by the Secretary. It shall state specifically the items of the partnership's gross income, the deductions allowed under the Code, each partner's distributive share of the partnership's income, and the adjustments required by this Part. A partner's distributive share of partnership net income includes any guaranteed payments made to the partner. The information return shall also include the name and address of each person who would be entitled to share in the partnership's net income, if distributable, and the amount each person's distributive share would be. The information return shall be signed by one of the partners under affirmation in the form required by the Secretary. A partnership that files an information return under this subsection shall furnish to each person who would be entitled to share in the partnership's net income, if distributable, any information necessary for that person to properly file a State income tax return. The information shall be in the form prescribed by the Secretary and must be furnished on or before the due date of the information return. A partnership that is not doing business in this State because it is a nonresident business performing disaster-related work during a disaster response period at the request of a critical infrastructure company is not required to file an information return with the Secretary. However, the partnership must furnish to each person who would be entitled to share in the partnership's net income, if distributable, any information necessary for that person to properly file a State income tax return. The definitions and provisions in G.S. 166A-19.70A apply to this paragraph.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-154.html/5a44e01b68e93bae409958dca79b6829f1ec99e06084c0872567fe34dfbc9703.html",
          "source_sha256": "5a44e01b68e93bae409958dca79b6829f1ec99e06084c0872567fe34dfbc9703",
          "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-154.html"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The election is made on the entity's timely filed return and cannot be made or revoked after that return is filed.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-131.1A(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(Effective for taxable years beginning on or after January 1, 2023) Taxed S Corporation Election. - An S Corporation may elect, on its timely filed return required under G.S. 105-131.7, to have the tax under this Article imposed on the S Corporation for any taxable period covered by the return. An S Corporation may not make or revoke the election after the return is filed.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-131.1A.html/7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66.html",
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      "source_class": "S1",
      "source_sha256": "7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
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    "holding_tax:pp-holding-entity-tax#NC.llc.filing_rule.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A corporation meeting the holding-company test must file a return, determine total net worth, and apportion that net worth to North Carolina.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-120.2(a)(1)-(3)",
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      "publish_status": "publish_ready",
      "quote": "Every corporation, domestic and foreign, incorporated or, by an act, domesticated under the laws of this State or doing business in this State that, at the close of its taxable year, is a holding company as defined in subsection (c) of this section, shall, pursuant to the provisions of G.S. 105-122, do all of the following: (1) File a return. (2) Determine the total amount of its net worth. (3) Apportion its net worth to this State.",
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      "source_class": "S1",
      "source_sha256": "8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NC.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "State net income tax applies to every C corporation doing business in North Carolina; the 2026 rate shown is 2%.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-130.3",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax is imposed on the State net income of every C Corporation doing business in this State. An S Corporation is not subject to the tax levied in this section. The tax is a percentage of the taxpayer's State net income computed as follows: Taxable Years Beginning Tax In 2025 2.25% In 2026 2% In 2028 1% After 2029 0%.",
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      "source_class": "S1",
      "source_sha256": "590cd4b90fb4d9aebcceb4aebeef008b20afcec3e6ec9cda80addfe82cdfdefe",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.3.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "evidence_role": "partnership_imposition",
          "pinpoint": "N.C. Gen. Stat. § 105-154.1(b)",
          "quote": "Taxable Income of Taxed Partnership. - A tax is imposed for the taxable period on the North Carolina taxable income of a taxed partnership. The tax shall be levied, collected, and paid annually. The tax is imposed on the North Carolina taxable income at the rate levied in G.S. 105-153.7. The North Carolina taxable income of a taxed partnership is determined as follows: (1) The North Carolina taxable income of a taxed partnership with respect to such taxable period shall be equal to the sum of the following for partners defined under G.S. 105-154.1(a)(1) through G.S. 105-154.1(a)(4): a. Each partner's distributive share of the taxed partnership's income or loss, subject to the adjustments provided in G.S. 105-153.5 and G.S. 105-153.6, attributable to the State. b. (Repealed effective for taxable years beginning on or after January 1, 2023) Each resident partner's distributive share of the taxed partnership's income or loss, subject to the adjustments provided in G.S. 105-153.5 and G.S. 105-153.6, not attributable to the State with respect to such taxable period. (2) Separately stated items of deduction are not included when calculating each partner's distributive share of the taxed partnership's taxable income. For purposes of this subdivision, separately stated items are those items described in section 702 of the Code and the regulations adopted under it. (3) The adjustments required by G.S. 105-153.5(c3) are not included in the calculation of the taxed partnership's taxable income.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-154.1.html/NC/757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b.html",
          "source_sha256": "757fc69de1ee9ba4aab7138a783eaa268850434496c6c89b235370edafac3a5b",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "An electing taxed S corporation or taxed partnership pays annual tax on North Carolina taxable income at the § 105-153.7 rate.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-131.1A(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Taxable Income of Taxed S Corporation. - A tax is imposed for the taxable period on the North Carolina taxable income of a taxed S Corporation. The tax shall be levied, collected, and paid annually. The tax is imposed on the North Carolina taxable income at the rate levied in G.S. 105-153.7. The North Carolina taxable income of a taxed S Corporation is determined as follows: (1) The North Carolina taxable income of a taxed S Corporation with respect to such taxable period shall be equal to the sum of the following: a. Each shareholder's pro rata share of the taxed S Corporation's income or loss, subject to the adjustments provided in G.S. 105-153.5 and G.S. 105-153.6, attributable to the State. b. (Repealed effective for taxable years beginning on or after January 1, 2023) Each resident shareholder's pro rata share of the taxed S Corporation's income or loss, subject to the adjustments provided in G.S. 105-153.5 and G.S. 105-153.6, not attributable to the State with respect to such taxable period. (2) Separately stated items of deduction are not included when calculating each shareholder's pro rata share of the taxed S Corporation's taxable income. For purposes of this subdivision, separately stated items are those items described in section 1366 of the Code and the regulations under it. (3) The adjustments required by G.S. 105-153.5(c3) are not included in the calculation of the taxed S Corporation's taxable income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-131.1A.html/7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66.html",
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      "source_class": "S1",
      "source_sha256": "7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.tax_regime.franchise_tax": {
      "additional_sources": [
        {
          "evidence_role": "holding_company_rate",
          "pinpoint": "N.C. Gen. Stat. § 105-120.2(b), taxable years beginning on or after January 1, 2025",
          "quote": "(Effective for taxable years beginning on or after January 1, 2025) Tax Rate. - Every corporation taxed under this section shall annually pay to the Secretary of Revenue, at the time the return is due, a franchise or privilege tax at the rate of one dollar and fifty cents ($1.50) per one thousand dollars ($1,000) of its tax base with a maximum of five hundred dollars ($500.00) for the first one million dollars ($1,000,000) of the corporation's tax base as determined under subsection (a) of this section, but in no case shall the tax be more than one hundred fifty thousand dollars ($150,000) nor less than two hundred dollars ($200.00).",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-120.2.html/NC/8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388.html",
          "source_sha256": "8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388",
          "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-122(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Tax Imposed. - An annual franchise or privilege tax is imposed on a corporation doing business in this State for the privilege of doing business in this State and for the continuance of articles of incorporation or domestication of each corporation in this State. A corporation subject to the tax must file a return under affirmation with the Secretary at the place and in the manner prescribed by the Secretary. The return must be signed by the president, vice-president, treasurer, or chief financial officer of the corporation. The return is due on or before the fifteenth day of the fourth month following the end of the corporation's income year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-122.html/b0248e51a17037dc819ff2ccff44508d452670511a045ac5ca2ac4d286e0e846.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b0248e51a17037dc819ff2ccff44508d452670511a045ac5ca2ac4d286e0e846",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-122.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Specified dividend and foreign-income amounts are deducted from federal taxable income, net of related expenses.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-130.5(b)(3a)-(3b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Dividends treated as received from sources outside the United States as determined under section 862 of the Code, net of related expenses, to the extent included in federal taxable income. Notwithstanding the proviso in subdivision (c)(3) of this section, the netting of related expenses shall be calculated in accordance with subdivision (c)(3) of this section. (3b) Any amount included in federal taxable income under section 78, 951, 951A, or 965 of the Code, net of related expenses.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-130.5.html/NC/bfa6a001c806b6b53af5a28d9048688f8042bcffb07176db0c5a233acba06596.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bfa6a001c806b6b53af5a28d9048688f8042bcffb07176db0c5a233acba06596",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.5.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "No holding-entity or passive-income carve-out was located in the two election sections; the regime is elective.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-131.1A.html/7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7b4d0ae310a537194e3aa0b12625e160ddfe95a06da8c5dfe8c7c1a9763e2c66",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NC.llc.treatment.franchise_tax": {
      "additional_sources": [
        {
          "evidence_role": "replacement_rule",
          "pinpoint": "N.C. Gen. Stat. § 105-120.2(e)",
          "quote": "Counties, cities and towns shall not levy a franchise tax on corporations taxed under this section. The tax imposed under the provisions of G.S. 105-122 shall not apply to businesses taxed under the provisions of this section.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-120.2.html/NC/8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388.html",
          "source_sha256": "8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388",
          "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A qualifying holding company pays under § 105-120.2's special base limits and is not also taxed under the general § 105-122 rule.",
      "fetch_event_id": null,
      "pinpoint": "N.C. Gen. Stat. § 105-120.2(b), (e)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(Effective for taxable years beginning on or after January 1, 2025) Tax Rate. - Every corporation taxed under this section shall annually pay to the Secretary of Revenue, at the time the return is due, a franchise or privilege tax at the rate of one dollar and fifty cents ($1.50) per one thousand dollars ($1,000) of its tax base with a maximum of five hundred dollars ($500.00) for the first one million dollars ($1,000,000) of the corporation's tax base as determined under subsection (a) of this section, but in no case shall the tax be more than one hundred fifty thousand dollars ($150,000) nor less than two hundred dollars ($200.00).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NC/snapshots/c50/NC/sec105-120.2.html/NC/8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8d99fe5371ea25616a7f48658f04ee36eb2567b3dff69c58d5ab5d1a0a70c388",
      "source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#ND.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporate income-tax rate brackets and taxable-income base are located at N.D.C.C. § 57-38-30.",
      "fetch_event_id": null,
      "pinpoint": "N.D.C.C. § 57-38-30",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax is hereby imposed upon the taxable income of every domestic and foreign corporation which must be levied, collected, and paid annually as in this chapter provided:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ND/snapshots/c50/ND/2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979",
      "source_url": "https://ndlegis.gov/cencode/t57c38.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#ND.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "N.D.C.C. § 57-38-08",
          "quote": "Partnerships are not subject to tax under this chapter. Persons carrying on a business as partners are taxable on their respective shares of the partnership's income, gain, loss, and deduction included in the partner's federal taxable income, as provided under section 57-38-08.1.",
          "role": "noncorporate LLC classifications",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/ND/snapshots/c50/ND/2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979.pdf",
          "source_sha256": "2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979",
          "source_url": "https://ndlegis.gov/cencode/t57c38.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.D.C.C. § 57-38-14(6)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax commissioner may permit or require the filing of a combined report if substantially all the voting capital stock of two or more corporations liable to report under this chapter is owned or controlled by the same interests. The tax commissioner may impose the tax provided by this chapter as though the combined entire income and segregated assets were those of one corporation, but in the computation, dividends received from any corporation whose assets, as distinguished from shares of stock, are included in the segregations may not be included in the income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ND/snapshots/c50/ND/2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979",
      "source_url": "https://ndlegis.gov/cencode/t57c38.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#ND.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current corporate levy, LLC-classification, combined-report dividend, and filing provisions do not state an effective or sunset period.",
      "fetch_event_id": null,
      "pinpoint": "N.D.C.C. Chapter 57-38, complete search",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ND/snapshots/c50/ND/2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979",
      "source_url": "https://ndlegis.gov/cencode/t57c38.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#ND.llc.filing_rule.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "N.D.C.C. § 57-38-32",
          "quote": "Any foreign loan and investment company engaged in business in this state, and whose income in this state consists solely of income exempt from taxation under this chapter, need not file an annual report unless specially requested to do so by the tax commissioner, but may file in lieu thereof an affidavit claiming exemption under this chapter.",
          "role": "foreign loan and investment company rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/ND/snapshots/c50/ND/2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979.pdf",
          "source_sha256": "2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979",
          "source_url": "https://ndlegis.gov/cencode/t57c38.pdf"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.D.C.C. § 57-38-32",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each corporation that receives income from the sources designated in section 57-38-14, whether or not required to file an income tax return pursuant to the provisions of the United States Internal Revenue Code of 1954, as amended, shall, unless exempted by the provisions of section 57-38-09, make a return in such form as the tax commissioner may prescribe, stating specifically such facts as the tax commissioner may require for the purpose of making any computation required by this chapter.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/ND/snapshots/c50/ND/2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979.pdf",
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      "source_class": "S1",
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      "source_url": "https://ndlegis.gov/cencode/t57c38.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#ND.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "North Dakota imposes an annual tax on the taxable income of every domestic and foreign corporation.",
      "fetch_event_id": null,
      "pinpoint": "N.D.C.C. § 57-38-30",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax is hereby imposed upon the taxable income of every domestic and foreign corporation which must be levied, collected, and paid annually as in this chapter provided:",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2429bef99ad1fccf9bc14f4e0d4cbb11948c3798fbadc3326677fd34c5e42979",
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      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#ND.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "In the permitted or required combined computation, dividends from a corporation whose assets are included may not be included in income.",
      "fetch_event_id": null,
      "pinpoint": "N.D.C.C. § 57-38-14(6)",
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      "publish_status": "publish_ready",
      "quote": "The tax commissioner may permit or require the filing of a combined report if substantially all the voting capital stock of two or more corporations liable to report under this chapter is owned or controlled by the same interests. The tax commissioner may impose the tax provided by this chapter as though the combined entire income and segregated assets were those of one corporation, but in the computation, dividends received from any corporation whose assets, as distinguished from shares of stock, are included in the segregations may not be included in the income.",
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    "holding_tax:pp-holding-entity-tax#NE.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The corporate income-tax base and rate schedule are located at Neb. Rev. Stat. § 77-2734.02(1); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Neb. Rev. Stat. § 77-2734.02(1)",
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      "publish_status": "publish_ready",
      "quote": "Except as provided in subsection (2) of this section, a tax is hereby imposed on the taxable income of every corporate taxpayer that is doing business in this state:",
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      "source_sha256": "dc107af8f85fee2477e40ad3a8b2b106eb2d53e44bb327d1a416524ddb07fa7e",
      "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
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    "holding_tax:pp-holding-entity-tax#NE.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Neb. Rev. Stat. § 77-2734.01(8)(b)",
          "quote": "An electing small business corporation with respect to a taxable period shall pay an income tax equivalent to the highest individual income tax rate provided in section 77-2715.03 multiplied by the electing small business corporation's net income as apportioned or allocated to this state in accordance with the Nebraska Revenue Act of 1967, for such taxable period;",
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      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The partnership and S-corporation PTET base and rate references are located at Neb. Rev. Stat. §§ 77-2727(6)(b) and 77-2734.01(8)(b); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Neb. Rev. Stat. § 77-2727(6)(b)",
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      "quote": "An electing partnership with respect to a taxable period shall pay an income tax equivalent to the highest individual income tax rate provided in section 77-2715.03 multiplied by the electing partnership's net income as apportioned or allocated to this state in accordance with the Nebraska Revenue Act of 1967, for such taxable period;",
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    "holding_tax:pp-holding-entity-tax#NE.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "regulation",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "REG-24-001.01",
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      "publish_status": "publish_ready",
      "quote": "Any corporation or any other entity taxed as a corporation under the Internal Revenue Code whether foreign, domestic or domesticated shall be subject to the Nebraska income tax; provided such corporate entity is not exempt under the provisions of Public Law 86-272 (15 U.S.C.A. 381-384, 1959) or is not a financial institution, and has part of its federal taxable income derived from sources within Nebraska.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-dor-reg-chapter-24-corporate-income-tax.html",
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      "source_sha256": "be73ba22e15a0b73b45e5fb667cb907b55ae8ba5b8b115416ebefbb3ec8068cc",
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    "holding_tax:pp-holding-entity-tax#NE.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Neb. Rev. Stat. § 77-2734.01(9)(b)",
          "quote": "Eligible small business corporation means an entity subject to taxation under subchapter S of the Internal Revenue Code and the regulations thereunder.",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Neb. Rev. Stat. § 77-2727(7)(b)",
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      "quote": "Eligible partnership means any partnership as provided for in section 7701(a)(2) of the Internal Revenue Code that has a filing requirement under the Nebraska Revenue Act of 1967 other than a publicly traded partnership as defined in section 7704 of the Internal Revenue Code. An eligible partnership includes any entity, including a limited liability company, treated as a partnership for federal income tax purposes that otherwise meets the requirements of this subdivision.",
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      "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2727",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NE.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The current statute states schedules for tax years beginning in 2026 and for tax years beginning on or after January 1, 2027.",
      "fetch_event_id": null,
      "pinpoint": "Neb. Rev. Stat. § 77-2734.02(1)(g)-(h)",
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      "publish_status": "publish_ready",
      "quote": "For taxable years beginning or deemed to begin on or after January 1, 2027",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-stat-77-2734-02.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NE.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "The Department states that eligible partnerships and S corporations may elect PTET for tax years beginning on and after January 1, 2018.",
      "fetch_event_id": null,
      "pinpoint": "General Information",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An eligible partnership or S corporation may elect to be subject to Nebraska income tax for tax years beginning on and after January 1, 2018. Once the election is made for a tax year the election is irrevocable and binding on the pass-through entity (PTE) and its owners. This irrevocable election cannot be changed by amending a return.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-dor-pass-through-entity-tax-ptet.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d1753440f970acd3eaeff2299dce1b93cb7945f96f6191e9b2ec80ec295ed58b",
      "source_url": "https://revenue.nebraska.gov/tax-credits/nebraska-pass-through-entity-tax-ptet",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NE.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Each corporate taxpayer files one Nebraska income-tax return for each taxable year.",
      "fetch_event_id": null,
      "pinpoint": "Neb. Rev. Stat. § 77-2734.02(4)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each corporate taxpayer shall file only one income tax return for each taxable year.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-stat-77-2734-02.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "dc107af8f85fee2477e40ad3a8b2b106eb2d53e44bb327d1a416524ddb07fa7e",
      "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NE.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "official_guidance",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "General Information, current tax year elections",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Current tax year elections can be made by either submitting the Pass-Through Entity Tax (PTET) Election for Tax Years After 2022, Form PTET-E, or by checking box 5 on the applicable income tax return. Remember box 5 must be checked on the return even if you submitted the Form PTET-E.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-dor-pass-through-entity-tax-ptet.html",
      "snapshot_resolved": true,
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      "source_sha256": "d1753440f970acd3eaeff2299dce1b93cb7945f96f6191e9b2ec80ec295ed58b",
      "source_url": "https://revenue.nebraska.gov/tax-credits/nebraska-pass-through-entity-tax-ptet",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NE.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Nebraska imposes income tax on the taxable income of every corporate taxpayer doing business in the state.",
      "fetch_event_id": null,
      "pinpoint": "Neb. Rev. Stat. § 77-2734.02(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as provided in subsection (2) of this section, a tax is hereby imposed on the taxable income of every corporate taxpayer that is doing business in this state:",
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      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-stat-77-2734-02.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "dc107af8f85fee2477e40ad3a8b2b106eb2d53e44bb327d1a416524ddb07fa7e",
      "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NE.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Neb. Rev. Stat. § 77-2734.01(8)(a)-(b)",
          "quote": "For tax years beginning or deemed to begin on or after January 1, 2018, a small business corporation may annually make an irrevocable election to pay the taxes, interest, or penalties levied by the Nebraska Revenue Act of 1967 at the entity level for the taxable period covered by such return. [...] An electing small business corporation with respect to a taxable period shall pay an income tax equivalent to the highest individual income tax rate provided in section 77-2715.03 multiplied by the electing small business corporation's net income as apportioned or allocated to this state in accordance with the Nebraska Revenue Act of 1967, for such taxable period;",
          "role": "parallel_s_corporation_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-stat-77-2734-01.html",
          "source_sha256": "6f0129ec939baf9d30206135d8fdf5e5567f432b7e6578ab3dcd73bd921640b5",
          "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.01"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "An eligible partnership or S corporation may irrevocably elect for a tax year to pay Nebraska income tax at the entity level.",
      "fetch_event_id": null,
      "pinpoint": "Neb. Rev. Stat. § 77-2727(6)(a)-(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For tax years beginning or deemed to begin on or after January 1, 2018, a partnership may annually make an irrevocable election to pay the taxes, interest, or penalties levied by the Nebraska Revenue Act of 1967 at the entity level for the taxable period covered by such return. [...] An electing partnership with respect to a taxable period shall pay an income tax equivalent to the highest individual income tax rate provided in section 77-2715.03 multiplied by the electing partnership's net income as apportioned or allocated to this state in accordance with the Nebraska Revenue Act of 1967, for such taxable period;",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/c50/ne-stat-77-2727.html/NE/936aa9ea4e45c1d37294fdbfe1dcee7c43323e0286a4a524fe010d6d20b96231.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2727",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NE.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "regulation",
      "display": "The general rule reaches a corporate-classified entity with Nebraska-source federal taxable income; no general holding/passive carve-out was located.",
      "fetch_event_id": null,
      "pinpoint": "REG-24-001.01",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Any corporation or any other entity taxed as a corporation under the Internal Revenue Code whether foreign, domestic or domesticated shall be subject to the Nebraska income tax; provided such corporate entity is not exempt under the provisions of Public Law 86-272 (15 U.S.C.A. 381-384, 1959) or is not a financial institution, and has part of its federal taxable income derived from sources within Nebraska.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-dor-reg-chapter-24-corporate-income-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "be73ba22e15a0b73b45e5fb667cb907b55ae8ba5b8b115416ebefbb3ec8068cc",
      "source_url": "https://revenue.nebraska.gov/about/legal-information/regulations/chapter-24-corporate-income-tax",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NE.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Neb. Rev. Stat. § 77-2734.01(8)(b)",
          "quote": "An electing small business corporation with respect to a taxable period shall pay an income tax equivalent to the highest individual income tax rate provided in section 77-2715.03 multiplied by the electing small business corporation's net income as apportioned or allocated to this state in accordance with the Nebraska Revenue Act of 1967, for such taxable period;",
          "role": "parallel_s_corporation_base",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/ne-stat-77-2734-01.html",
          "source_sha256": "6f0129ec939baf9d30206135d8fdf5e5567f432b7e6578ab3dcd73bd921640b5",
          "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.01"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Neb. Rev. Stat. § 77-2727(6)(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An electing partnership with respect to a taxable period shall pay an income tax equivalent to the highest individual income tax rate provided in section 77-2715.03 multiplied by the electing partnership's net income as apportioned or allocated to this state in accordance with the Nebraska Revenue Act of 1967, for such taxable period;",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NE/snapshots/c50/ne-stat-77-2727.html/NE/936aa9ea4e45c1d37294fdbfe1dcee7c43323e0286a4a524fe010d6d20b96231.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "936aa9ea4e45c1d37294fdbfe1dcee7c43323e0286a4a524fe010d6d20b96231",
      "source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2727",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.base_tax_locator.business_enterprise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The Business Enterprise Tax rate and base are set by RSA 77-E:2 and RSA 77-E:1, IX and XV; no amount is given here.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-E:2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "II. For all taxable periods ending on or after December 31, 2022, a tax is imposed at the rate of 0.55 percent upon the taxable enterprise value tax base of every business enterprise.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077e-business-enterprise-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a0210192488137395371426dbfe866bb065429b8777380418690c588f2206785",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.base_tax_locator.business_profits_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The Business Profits Tax rate and base are set by RSA 77-A:2 and RSA 77-A:1, III-IV; no amount is given here.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-A:2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "III. For all taxable periods ending on or after December 31, 2023, a tax is imposed at the rate of 7.5 percent upon the taxable business profits of every business organization.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077a-business-profits-tax.html",
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      "source_class": "S1",
      "source_sha256": "7cf57326d4c3a02f53aa884c2b3f1f681131321d67d09b4c04fb9ad6bca6c16e",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NH.llc.does_not_reach.business_enterprise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-E:1, XIV(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) A qualified investment company shall limit its activities to investment or other activities consistent with its organizational purpose and those incidental to or in support of such activities provided that any such exception from investment company status by reason of section 3(c)(7) is available only to issuers whose securities are owned by persons or organizations who are deemed under section 3(c)(7) or any order, regulation or interpretation thereunder not to require protection under the provisions of the Investment Company Act by reason of their size, nature, status, or sophistication. A business organization seeking qualified investment company status shall file an election pursuant to RSA 77-A:5-b.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077e-business-enterprise-tax.html",
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      "source_class": "S1",
      "source_sha256": "a0210192488137395371426dbfe866bb065429b8777380418690c588f2206785",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.does_not_reach.business_profits_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-A:1, XXI(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) A qualified investment company shall limit its activities to investment or other activities consistent with its organizational purpose and those incidental to or in support of such activities provided that any such exception from investment company status by reason of section 3(c)(7) is available only to issuers whose securities are owned by persons or organizations who are deemed under section 3(c)(7) or any order, regulation or interpretation thereunder not to require protection under the provisions of the Investment Company Act by reason of their size, nature, status, or sophistication. A business organization seeking qualified investment company status shall file an election pursuant to RSA 77-A:5-b.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077a-business-profits-tax.html",
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      "source_class": "S1",
      "source_sha256": "7cf57326d4c3a02f53aa884c2b3f1f681131321d67d09b4c04fb9ad6bca6c16e",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.effective_period.business_enterprise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The current 0.55 percent BET rate applies to taxable periods ending on or after December 31, 2022; no sunset date is stated.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-E:2, II",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "II. For all taxable periods ending on or after December 31, 2022, a tax is imposed at the rate of 0.55 percent upon the taxable enterprise value tax base of every business enterprise.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077e-business-enterprise-tax.html",
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      "source_class": "S1",
      "source_sha256": "a0210192488137395371426dbfe866bb065429b8777380418690c588f2206785",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NH.llc.effective_period.business_profits_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The current 7.5 percent BPT rate applies to taxable periods ending on or after December 31, 2023; no sunset date is stated.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-A:2, III",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "III. For all taxable periods ending on or after December 31, 2023, a tax is imposed at the rate of 7.5 percent upon the taxable business profits of every business organization.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077a-business-profits-tax.html",
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      "source_class": "S1",
      "source_sha256": "7cf57326d4c3a02f53aa884c2b3f1f681131321d67d09b4c04fb9ad6bca6c16e",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.filing_rule.business_enterprise_tax": {
      "additional_sources": [
        {
          "pinpoint": "DRA 'Business Taxes' page, BET paragraph",
          "quote": "The  Business Enterprise Tax (BET) was enacted in 1993. The tax is assessed on the taxable enterprise value tax base, which is the sum of all compensation paid or accrued, interest paid or accrued, and dividends paid by the business enterprise at the rate of .55% for taxable periods ending on or after December 31, 2022.  For taxable periods beginning on or after January 1, 2025, every business enterprise with more than $298,000 of gross receipts from all activities, or an enterprise value tax base of more than $298,000, must file a BET return. The filing threshold is adjusted biennially.",
          "role": "corroborating_context",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-dra-business-taxes.html",
          "source_sha256": "71ada03e21afc00a906c9e7652cb407d150bd9a00b3af3086ba19436395fcf90",
          "source_url": "https://www.revenue.nh.gov/taxes-glance/business-taxes"
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-E:5, I",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "I. Every business enterprise having gross business receipts in excess of $250,000 as defined by RSA 77-E:1, X, during the taxable period or the enterprise value tax base of which is greater than $250,000 shall, on or before the fifteenth day of the third month in the case of enterprises required to file a United States partnership tax return, the fifteenth day of the fifth month in the case of enterprises required to file a United States exempt organization return, and the fifteenth day of the fourth month in the case of all other business enterprises, following expiration of its taxable period, make a return to the commissioner. For tax years beginning January 1, 2015, the commissioner shall biennially adjust these threshold amounts rounding to the nearest $1,000 based on the 2-year (24-month) percentage change in the Consumer Price Index for All Urban Consumers, Northeast Region as published by the Bureau of Labor Statistics, United States Department of Labor using the amount published for the month of June in the year prior to the start of the tax year. All returns shall be signed by the business enterprise or by its authorized representative, subject to the pains and penalties of perjury and the penalties provided in RSA 21-J:39. […] The  Business Enterprise Tax (BET) was enacted in 1993. The tax is assessed on the taxable enterprise value tax base, which is the sum of all compensation paid or accrued, interest paid or accrued, and dividends paid by the business enterprise at the rate of .55% for taxable periods ending on or after December 31, 2022.  For taxable periods beginning on or after January 1, 2025, every business enterprise with more than $298,000 of gross receipts from all activities, or an enterprise value tax base of more than $298,000, must file a BET return. The filing threshold is adjusted biennially.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077e-business-enterprise-tax.html",
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      "source_class": "S1",
      "source_sha256": "a0210192488137395371426dbfe866bb065429b8777380418690c588f2206785",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.filing_rule.business_profits_tax": {
      "additional_sources": [
        {
          "pinpoint": "DRA 'Business Taxes' page, BPT paragraph",
          "quote": "The  Business Profits Tax (BPT) was enacted in 1970. The tax is assessed on the taxable business profits of business organizations conducting business activity within the state. The tax rate is 7.6% for taxable periods ending on or after December 31, 2022, and 7.5% for taxable periods ending on or after December 31, 2023. For multi-state businesses, for taxable periods ending before December 31, 2022, income is apportioned using a weighted sales factor of two and the standard payroll and property factors. For taxable periods ending on or after December 31, 2022, income is apportioned using single sales factor. Organizations operating a unitary business must use combined reporting in filing their NH return. For taxable periods beginning on or after January 1, 2025, every business organization with gross business income from all business activities of more than $109,000 must file a BPT return. The filing threshold is adjusted biennially.",
          "role": "corroborating_context",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-dra-business-taxes.html",
          "source_sha256": "71ada03e21afc00a906c9e7652cb407d150bd9a00b3af3086ba19436395fcf90",
          "source_url": "https://www.revenue.nh.gov/taxes-glance/business-taxes"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-A:6, I",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "I. Every business organization having gross business income in excess of $92,000 as defined by RSA 77-A:1, VI, during the taxable period, shall on or before the fifteenth day of the third month in the case of organizations required to file a United States partnership tax return, the fifteenth day of the fifth month in the case of organizations required to file a United States exempt organization tax return, and the fifteenth day of the fourth month in the case of all other business organizations, following expiration of its taxable period, make a return to the commissioner. For tax years beginning January 1, 2023, the commissioner shall biennially adjust this threshold amount rounding to the nearest $1,000 based on the 2-year (24-month) percentage change in the Consumer Price Index for All Urban Consumers, Northeast Region as published by the Bureau of Labor Statistics, United States Department of Labor using the amount published for the month of June in the year prior to the start of the tax year. The commissioner shall adopt rules, pursuant to RSA 541-A, relative to the form of such return and the data which it must contain for the correct computation of taxable business profits and gross business income attributable to this state and the tax assessed on it. All returns shall be signed by the taxpayer or by its authorized representative, subject to the pains and penalties of perjury. […] The  Business Profits Tax (BPT) was enacted in 1970. The tax is assessed on the taxable business profits of business organizations conducting business activity within the state. The tax rate is 7.6% for taxable periods ending on or after December 31, 2022, and 7.5% for taxable periods ending on or after December 31, 2023. For multi-state businesses, for taxable periods ending before December 31, 2022, income is apportioned using a weighted sales factor of two and the standard payroll and property factors. For taxable periods ending on or after December 31, 2022, income is apportioned using single sales factor. Organizations operating a unitary business must use combined reporting in filing their NH return. For taxable periods beginning on or after January 1, 2025, every business organization with gross business income from all business activities of more than $109,000 must file a BPT return. The filing threshold is adjusted biennially. […] II. Every business organization electing treatment as a qualified investment company shall, with respect to each taxable period, file a report, in accordance with such rules or forms as the commissioner may prescribe, setting forth the following:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077a-business-profits-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7cf57326d4c3a02f53aa884c2b3f1f681131321d67d09b4c04fb9ad6bca6c16e",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.tax_regime.business_enterprise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-E:2, II",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "II. For all taxable periods ending on or after December 31, 2022, a tax is imposed at the rate of 0.55 percent upon the taxable enterprise value tax base of every business enterprise.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077e-business-enterprise-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a0210192488137395371426dbfe866bb065429b8777380418690c588f2206785",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.tax_regime.business_profits_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-A:2, III",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "III. For all taxable periods ending on or after December 31, 2023, a tax is imposed at the rate of 7.5 percent upon the taxable business profits of every business organization.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077a-business-profits-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7cf57326d4c3a02f53aa884c2b3f1f681131321d67d09b4c04fb9ad6bca6c16e",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.treatment.business_enterprise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-E:1, III",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "III. \"Business enterprise\" means any profit or nonprofit enterprise or organization, whether corporation, partnership, limited liability company, proprietorship, association, trust, foundation, business trust, real estate trust or other form of organization engaged in or carrying on any business activity within this state, except such enterprises as are expressly made exempt from income taxation under section 501(c)(3) of the United States Internal Revenue Code to the extent such enterprise does not engage in any business activity constituting unrelated business activity as defined by section 513 of the United States Internal Revenue Code. Each business enterprise under this definition shall be subject to the tax imposed under RSA 77-E as a separate entity except that trusts and foundations treated as grantor trusts under section 671 of the United States Internal Revenue Code shall be included in the return of their owners, and such owners shall be subject to the tax thereon to the extent any such owners would be considered a business enterprise hereunder notwithstanding the existence of the trust or foundation. The use of consolidated returns as defined in the United States Internal Revenue Code or of combined reporting is not permitted. Notwithstanding any other provision of this paragraph, an enterprise shall not be characterized as a business enterprise and shall be excluded from taxation at the entity level if it is a qualified investment company as defined in RSA 77-E:1, XIV or if it is a qualified regenerative manufacturing company as defined in RSA 77-E:1, XIV-a.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077e-business-enterprise-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a0210192488137395371426dbfe866bb065429b8777380418690c588f2206785",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NH.llc.treatment.business_profits_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RSA 77-A:1, I",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "I. \"Business organization\" means any enterprise, whether corporation, partnership, limited liability company, proprietorship, association, business trust, real estate trust or other form of organization; organized for gain or profit, carrying on any business activity within the state, except such enterprises as are expressly made exempt from income taxation under the United States Internal Revenue Code as defined in RSA 77-A:1, XX. Each enterprise under this definition shall be subject to taxation under RSA 77-A:2 as a separate entity, unless specifically authorized by this chapter to be treated otherwise, such as, but not limited to, combined reporting. Trusts or foundations treated as grantor trusts under section 671 of the United States Internal Revenue Code shall be included in the return of their owners, and such owners shall be subject to the tax thereon to the extent such owners would be considered a business organization hereunder notwithstanding the existence of the trust or foundation. The use of consolidated returns as defined in the United States Internal Revenue Code as defined in RSA 77-A:1, XX is not permitted. Notwithstanding any other provision of this paragraph, an enterprise shall not be characterized as a business organization and shall be excluded from taxation at the entity level if it elects to be treated as a qualified investment company as defined in RSA 77-A:1, XXI or if it elects to be treated as a qualified regenerative manufacturing company as defined in RSA 77-A:1, XXX. A partnership, limited liability company, estate, trust, or foundation except grantor trusts pursuant to section 671 of the United States Internal Revenue Code, \"S\" corporation, real estate investment trust, or any other such entity, other than an organization electing to be treated as a qualified investment company as defined in RSA 77-A:1, XXI whose net income is reportable by the true owners either directly or indirectly, or an organization electing to be treated as a qualified regenerative manufacturing company as defined in RSA 77-A:1, XXX, shall be subject to tax at the entity level, and no part of such earnings or loss shall be included in the calculation of the gross business profits of the owners of such entity.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NH/snapshots/nh-code-077a-business-profits-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7cf57326d4c3a02f53aa884c2b3f1f681131321d67d09b4c04fb9ad6bca6c16e",
      "source_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.base_tax_locator.corporation_business_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The investment-company base is located at N.J.S.A. 54:10A-5(d) and the current CBT-100 instructions, Schedule A, Part III, line 2a.",
      "fetch_event_id": null,
      "pinpoint": "2025 CBT-100 Instructions, Schedule A, Part III, line 2a",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Qualified investment companies enter 40% of line 1.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/nj-tax-cbt100-instructions.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8b060a341194ca7db8cc5eacd684913c6c732ad716e5e2f5584cb43c1b7adca6",
      "source_url": "https://www.nj.gov/treasury/taxation/pdf/current/cbt/cbt100ins.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.base_tax_locator.nonresident_partner_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The nonresident-partner payment computation is located at N.J.S.A. 54:10A-15.11(a)(1).",
      "fetch_event_id": null,
      "pinpoint": "P.L. 2022, c.133, § 13; N.J.S.A. 54:10A-15.11(a)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A partnership that is not a qualified investment partnership or an investment club and that is not listed on a United States national stock exchange shall, on or before the 15th day of the fourth month succeeding the close of each privilege period, remit a payment of tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/c50/NJ/b981d3c3bfb4662a3b6402a9122e27cfbca053377efe8d7db9f47ab05f6248aa.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b981d3c3bfb4662a3b6402a9122e27cfbca053377efe8d7db9f47ab05f6248aa",
      "source_url": "https://pub.njleg.state.nj.us/Bills/2022/PL22/133_.PDF",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.base_tax_locator.partnership_filing_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The fee is located at N.J.S.A. 54A:8-6(b)(2)(A) and the Partnership Filing Fee schedule in Form NJ-1065.",
      "fetch_event_id": null,
      "pinpoint": "2025 NJ-1065 Instructions, Partnership Filing Fee",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Any entity classified as a partnership for federal income tax purposes, other than an investment club, that has any income or loss derived from New Jersey sources and that has more than two owners is required to make a payment of a filing fee of $150 for each owner of an interest in the entity up to a maximum of $250,000.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/nj-tax-nj1065-instructions.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "e10131c5cb0c7eda33cd7b30eb872f18ccf5359881663dd0daaf3259720566d8",
      "source_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.base_tax_locator.pass_through_business_alternative_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The PTE/BAIT base and rate table is located at N.J.S.A. 54A:12-3(b)(2).",
      "fetch_event_id": null,
      "pinpoint": "P.L. 2021, c.419, § 2; N.J.S.A. 54A:12-3(b)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax imposed on a pass-through entity pursuant to this section shall be determined in accordance with the following table with respect to the sum of each member's share of distributive proceeds attributable to the pass-through entity for the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/c50/NJ/8a6e2f8b64c2250e354b3ddf86991929ce42efba1215a877ce8084801bd46ba5.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8a6e2f8b64c2250e354b3ddf86991929ce42efba1215a877ce8084801bd46ba5",
      "source_url": "https://pub.njleg.state.nj.us/Bills/2020/PL21/419_.HTM",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.does_not_reach.corporation_business_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.J.S.A. 54:10A-4(hh)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For privilege periods ending on and after July 31, 2023, a captive investment company shall be taxed in the same manner as a C corporation, and subsection d. of section 5 of P.L. 1945, c. 162 (C. 54:10A-5) shall not apply.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/c50/NJ/6bf54d25889d2940e1b65a91b151d003ff7498e94801626068228fd5f749da82.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6bf54d25889d2940e1b65a91b151d003ff7498e94801626068228fd5f749da82",
      "source_url": "https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1/51481/52550",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.does_not_reach.nonresident_partner_tax": {
      "additional_sources": [
        {
          "pinpoint": "N.J.S.A. 54:10A-15.11(a)(1)",
          "quote": "A partnership that is not a qualified investment partnership or an investment club and that is not listed on a United States national stock exchange shall, on or before the 15th day of the fourth month succeeding the close of each privilege period, remit a payment of tax.",
          "role": "statutory_exclusion_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/c50/NJ/b981d3c3bfb4662a3b6402a9122e27cfbca053377efe8d7db9f47ab05f6248aa.pdf",
          "source_sha256": "b981d3c3bfb4662a3b6402a9122e27cfbca053377efe8d7db9f47ab05f6248aa",
          "source_url": "https://pub.njleg.state.nj.us/Bills/2022/PL22/133_.PDF"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "2025 NJ-CBT-1065 Instructions, Investment Clubs",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "If an investment club meets the following criteria, it will be exempt from the $150 per owner annual partnership filing fee and from the requirement that a partnership make payments on behalf of its nonresident owners. The investment club must be an entity that is classified as a partnership for federal income tax purposes, all of the owners are individuals, and all of the assets are securities, cash, or cash equivalents. The market value of the total assets of the investment club cannot exceed, as measured on the last day of its privilege period, an amount equal to the lesser of $442,000 or $61,900 per owner of the entity. The investment club is not required to register itself or its membership interests with the federal Securities and Exchange Commission.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/nj-tax-njcbt1065-instructions.pdf",
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      "source_class": "S1",
      "source_sha256": "ea4c3ea9cd89c3bc54f5c250e2372b8f376ff5fc5d4156c506d526d3fa5fb99f",
      "source_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/cbt1065i.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.does_not_reach.partnership_filing_fee": {
      "additional_sources": [
        {
          "pinpoint": "2025 NJ-1065 Instructions, Partnership Filing Fee",
          "quote": "Any entity classified as a partnership for federal income tax purposes, other than an investment club, that has any income or loss derived from New Jersey sources and that has more than two owners is required to make a payment of a filing fee of $150 for each owner of an interest in the entity up to a maximum of $250,000.",
          "role": "general_scope",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/nj-tax-nj1065-instructions.pdf",
          "source_sha256": "e10131c5cb0c7eda33cd7b30eb872f18ccf5359881663dd0daaf3259720566d8",
          "source_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The current instructions exclude qualifying investment clubs; the general fee rule also requires New Jersey-source income or loss and more than two owners.",
      "fetch_event_id": null,
      "pinpoint": "2025 NJ-1065 Instructions, Investment Clubs",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "If an investment club meets the following criteria, it will be exempt from the $150 per owner annual partnership filing fee and from the requirement that a partnership make payments on behalf of its nonresident owners. The investment club must be an entity that is classified as a partnership for federal income tax purposes, all of the owners are individuals, and all of the assets are securities, cash, or cash equivalents. The market value of the total assets do not exceed, as measured on the last day of its privilege period, an amount equal to the lesser of $442,000 or $61,900 per owner of the entity. The investment club is not required to register itself or its membership interests with the federal Securities and Exchange Commission.",
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      "source_class": "S1",
      "source_sha256": "e10131c5cb0c7eda33cd7b30eb872f18ccf5359881663dd0daaf3259720566d8",
      "source_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.does_not_reach.pass_through_business_alternative_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The election requires at least one individual, estate, or trust member liable under the Gross Income Tax Act on distributive proceeds.",
      "fetch_event_id": null,
      "pinpoint": "New Jersey Division of Taxation, PTE/BAIT overview — eligibility",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For New Jersey tax purposes, income and losses of a pass-through entity are passed through to its members. Eligible S corporations, partnerships, and LLCs classified as a partnership or an S corporation for federal tax purposes with at least one member who is an individual, estate, or trust who is liable for tax on their share of distributive proceeds subject to the New Jersey Gross Income Tax Act may elect to pay PTE/BAIT at the entity level on the sum of each member’s share of distributive proceeds.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/nj-tax-baitpte.html",
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      "source_class": "S1",
      "source_sha256": "b271482a9bd02aa0c98e0855bcdb76c7ae9c3a25c15342106595af1ed1dff61a",
      "source_url": "https://nj.gov/treasury/taxation/baitpte/index.shtml",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NJ.llc.effective_period.corporation_business_tax": {
      "additional_sources": [
        {
          "pinpoint": "2025 CBT-100 Instructions",
          "quote": "The 2025 Corporation Business Tax return should only be used for accounting periods ending on and after July 31, 2025, through June 30, 2026.",
          "role": "current_form_period",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NJ/snapshots/nj-tax-cbt100-instructions.pdf",
          "source_sha256": "8b060a341194ca7db8cc5eacd684913c6c732ad716e5e2f5584cb43c1b7adca6",
          "source_url": "https://www.nj.gov/treasury/taxation/pdf/current/cbt/cbt100ins.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The captive-investment-company limitation applies to privilege periods ending on and after July 31, 2023.",
      "fetch_event_id": null,
      "pinpoint": "N.J.S.A. 54:10A-4(hh)",
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      "display": "The entity-level tax rate and distributed-net-income base are located at NMSA 1978, § 7-3A-10(C)-(D).",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-3A-10(C)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "C. The entity-level tax is imposed on the distributed net income of the pass-through entity for the taxable year. The rate of entity-level tax is equal to the higher of the maximum tax rate imposed pursuant to Section 7-2-7 NMSA 1978 or the maximum tax rate imposed pursuant to Section 7-2A-5 NMSA 1978 for the taxable year.",
      "readiness": "ready",
      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
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    "holding_tax:pp-holding-entity-tax#NM.llc.base_tax_locator.gross_receipts_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The state gross-receipts-tax rate is located at NMSA 1978, § 7-9-4(A).",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-9-4(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. For the privilege of engaging in business, an excise tax equal to the following percentages of gross receipts is imposed on any person engaging in business in New Mexico: (1) prior to July 1, 2023, five percent; and (2) beginning July 1, 2023, four and seven-eighths percent, except as provided in Subsection C of this section. B. The tax imposed by this section shall be referred to as the \"gross receipts tax\".",
      "readiness": "ready",
      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
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      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NM.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The federal-special-deduction base rule does not remove state or local bond interest exempt under the IRC; New Mexico adds that interest back.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-2A-2(C)(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) interest received on a state or local bond exempt under the Internal Revenue Code;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NM.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-3A-10(D)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) less the amount of net capital gains that may be deducted pursuant to Section 7-2-34 NMSA 1978 and is properly allocated to owners who are subject to tax pursuant to the Income Tax Act [Chapter 7, Article 2 NMSA 1978].",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NM.llc.does_not_reach.gross_receipts_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The exemption is receipt-specific: interest on money loaned or deposited, dividends or interest from securities, and proceeds from securities sales.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-9-25",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "7-9-25. Exemption; gross receipts tax; dividends and interest. Exempted from the gross receipts tax are the receipts received as interest on money loaned or deposited, receipts received as dividends or interest from stocks, bonds or securities or receipts from the sale of stocks, bonds or securities.",
      "readiness": "ready",
      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NM.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The 2026 base-income amendment was effective May 20, 2026 and applies to taxable years beginning on or after January 1, 2027.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-2A-2 amendment and applicability notes",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The 2026 amendment, effective May 20, 2026, amended the definition of \"base income\" for the purpose of the Corporate Income and Franchise Tax Act; in Subsection C, Paragraph C(1), added Subparagraphs C(1)(e) and C(1)(f), and in Paragraph C(2), deleted former Subparagraph C(2)(c), which provided \"an amount equal to one hundred percent of the income of the corporation under Section 951A of he Internal Revenue Code, less the amount deducted pursuant to Section 250 of the Internal Revenue Code\". Applicability. — Laws 2026, ch. 69, § 11 provided that the provisions of Laws 2026, ch. 69, §§ 1 to 4 and 6 to 8 apply to taxable years beginning on or after January 1, 2027. Laws 2024, ch. 67, § 42 provided that the provisions of Laws 2024, ch. 67, §§ 5, 8, 10 and 32 through 37 apply to taxable years beginning on or after January 1, 2025.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NM.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The 2023 entity-level-tax amendments apply to taxable years beginning on or after January 1, 2023.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-3A-10 applicability note",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Applicability. — Laws 2023, ch. 159, § 5 provided that the provisions of Laws 2023, ch. 159 apply to taxable years beginning on or after January 1, 2023.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NM.llc.effective_period.gross_receipts_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The dividends, interest, and securities-sale exemption has been effective since July 1, 1969.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-9-25 effective-date note",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective dates. — Laws 1969, ch. 144, § 68 made Laws 1969, ch. 144, § 18 effective July 1, 1969.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NM.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A covered corporation must file the prescribed return and pay by the due date of its federal corporate income-tax return.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-2A-9(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. Every corporation deriving income from any business transaction, property or employment within this state, that is not exempt from tax under the Corporate Income and Franchise Tax Act and that is required by the laws of the United States to file a federal income tax return shall file a complete tax return with the department in form and content as prescribed by the secretary. A corporation that is required by the provisions of the Corporate Income and Franchise Tax Act to file a return or pay a tax shall, on or before the due date of the corporation's federal corporate income tax return for the taxable year, file the return and pay the tax imposed for that year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NM.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-3A-10(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "B. A pass-through entity electing to pay the entity-level tax shall make the election by filing a complete entity-level tax return with the department in the form and manner as prescribed by the department. The election shall be binding on all owners of the electing pass-through entity. The return shall be filed no later than the original or extended due date of the entity's federal partnership or S corporation return for the taxable year. Payment of the entity-level tax shall accompany or precede the filing of the return.",
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      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
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    },
    "holding_tax:pp-holding-entity-tax#NM.llc.filing_rule.gross_receipts_tax": {
      "additional_sources": [
        {
          "pinpoint": "NMSA 1978, § 7-9-11",
          "quote": "7-9-11. Date payment due. The taxes imposed by the Gross Receipts and Compensating Tax Act are to be paid on or before the twenty-fifth day of the month following the month in which the taxable event occurs.",
          "role": "statutory_payment_due_date",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
          "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
          "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Gross Receipts Tax Overview, Forms and Instructions",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The paper form and instructions to report gross receipts taxes are located at the bottom of this page. These documents contain a lot of useful information. We do however recommend that you file electronically using our Taxpayer Access Point (TAP) whenever possible, https://tap.state.nm.us/TAP/.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/nm-tax-gross-receipts.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "edb83af2bb30c4d37a66e8f72a0d057bf64441a62076052be6f58bfe3a32a012",
      "source_url": "https://www.tax.newmexico.gov/businesses/gross-receipts-overview/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NM.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Corporate income tax applies to a corporation doing business in New Mexico or deriving income from New Mexico property or employment.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-2A-3(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. A tax to be known as the \"corporate income tax\" is imposed at the rate specified in the Corporate Income and Franchise Tax Act upon the taxable income of a corporation or group of corporations, in whatever jurisdiction organized or incorporated, that is engaged in the transaction of business in, into or from this state or deriving any income from any property or employment within this state.",
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      "reason_code": null,
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      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
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    "holding_tax:pp-holding-entity-tax#NM.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "NMSA 1978, § 7-3A-10(A)",
          "quote": "A. A pass-through entity may elect on an annual basis to pay a tax at the entity level for a taxable year. The tax that may elected to be paid pursuant to this section may be referred to as the \"entity-level tax\".",
          "role": "annual_election",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
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      "display": "A pass-through entity may elect annually to pay entity-level tax; the tax is imposed on distributed net income.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-3A-10(C)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "C. The entity-level tax is imposed on the distributed net income of the pass-through entity for the taxable year. The rate of entity-level tax is equal to the higher of the maximum tax rate imposed pursuant to Section 7-2-7 NMSA 1978 or the maximum tax rate imposed pursuant to Section 7-2A-5 NMSA 1978 for the taxable year.",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Gross receipts tax is imposed on a person engaging in business in New Mexico, subject to the Act's exemptions and deductions.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-9-4(A)-(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. For the privilege of engaging in business, an excise tax equal to the following percentages of gross receipts is imposed on any person engaging in business in New Mexico: (1) prior to July 1, 2023, five percent; and (2) beginning July 1, 2023, four and seven-eighths percent, except as provided in Subsection C of this section. B. The tax imposed by this section shall be referred to as the \"gross receipts tax\".",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
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      "source_class": "S1",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "A corporation-classified LLC remains in the regime, but its New Mexico base begins after the federal special deductions in IRC §§ 241-249.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-2A-2(C)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "C. \"base income\" means the federal taxable income or the federal net operating loss of a corporation for the taxable year calculated pursuant to the Internal Revenue Code, after special deductions provided in Sections 241 through 249 of the Internal Revenue Code but without any deduction for net operating losses, as if the corporation filed a federal tax return as a separate domestic entity, modified as follows:",
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      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
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      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NM.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The entity remains subject to elective tax, but qualifying net capital gain is removed from distributed net income.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-3A-10(D)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) less the amount of net capital gains that may be deducted pursuant to Section 7-2-34 NMSA 1978 and is properly allocated to owners who are subject to tax pursuant to the Income Tax Act [Chapter 7, Article 2 NMSA 1978].",
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      "source_class": "S1",
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      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NM.llc.treatment.gross_receipts_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "An LLC remains within the gross-receipts regime, but the listed interest, dividend, and securities-sale receipts are exempt.",
      "fetch_event_id": null,
      "pinpoint": "NMSA 1978, § 7-9-25",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "7-9-25. Exemption; gross receipts tax; dividends and interest. Exempted from the gross receipts tax are the receipts received as interest on money loaned or deposited, receipts received as dividends or interest from stocks, bonds or securities or receipts from the sale of stocks, bonds or securities.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NM/snapshots/c50/NM/8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8769c2a4a62d444665499af4325f9e72a9173c09e1c14689a54f076cbc89e82c",
      "source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.base_tax_locator.commerce_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The tax is computed under NRS 363C.300 at the rate for the entity's business category (NRS 363C.310-363C.560, including NRS 363C.470 for management of companies and enterprises).",
      "fetch_event_id": null,
      "pinpoint": "NRS 363C.300 and NRS 363C.470, Chapter 363C, 'Calculation of Tax'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as otherwise provided in this section, the commerce tax required to be paid by a business entity engaging in a business in this State is equal to the amount obtained by subtracting $4,000,000 from the Nevada gross revenue of the business entity for the taxable year and multiplying that amount by the rate set forth in NRS 363C.310 to 363C.550, inclusive, for the business category in which the business entity is primarily engaged. If the business entity cannot be categorized in a business category set forth in NRS 363C.310 to 363C.550, inclusive, the commerce tax required to be paid by that business entity is equal to the amount obtained by subtracting $4,000,000 from the Nevada gross revenue of the business entity for the taxable year and multiplying that amount by the rate set forth in NRS 363C.560. […] 1. The management of companies and enterprises business category (NAICS 55) includes all business entities primarily engaged in: (a) Holding the securities of, or other equity interests in, companies and enterprises for the purpose of owning a controlling interest or influencing management decisions; or (b) Administering, overseeing and managing establishments of the company or enterprise and that normally undertake the strategic or organizational planning and decision-making role of the company or enterprise.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-363c-commerce-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7a746cd78156695763513302254569bf53a0a2563789acddf669c58b9f44d0a9",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.base_tax_locator.state_business_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The license fee is set in NRS 76.100(2)(c) and the annual renewal fee in NRS 76.130(1)-(2); penalties are in NRS 76.110, 76.130(4) and 76.180.",
      "fetch_event_id": null,
      "pinpoint": "NRS 76.130(1)-(2), Chapter 76",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "1. Except as otherwise provided in subsection 2, a person who applies for renewal of a state business license shall submit a fee in the amount of $200 to the Secretary of State: […] 2. If the person applying for the renewal of a state business license pursuant to subsection 1 is a corporation organized pursuant to chapter 78, 78A or 78B of NRS, or a foreign corporation required to file an initial or annual list with the Secretary of State pursuant to chapter 80 of NRS, the fee for the renewal of a state business license is $500.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-076-state-business-license.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9bc5e1d47997aedeb6e8bee704c12617dafeaa7718e79eaee6ed1a33335b8602",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.does_not_reach.commerce_tax": {
      "additional_sources": [
        {
          "pinpoint": "NAC 363C.210(2), (3) and (4)(a)",
          "quote": "2. Except as otherwise provided in subsection 3 and chapter 363C of NRS, for the purpose of determining whether a person or other entity is subject to the commerce tax, a person or other entity is a business entity if the person is: (a) An entity organized pursuant to title 7 of NRS or another equivalent statute of this State or another jurisdiction, other than an entity organized pursuant to chapter 82 or 84 of NRS. (b) A state, national, domestic or foreign bank, whether organized under the laws of this State, another state or another country, or under federal law. (c) A savings and loan association or savings bank, whether organized under the laws of this State, another state or another country, or under federal law. (d) A partnership governed by chapter 87 of NRS or another equivalent statute of this State or another jurisdiction. (e) A registered limited-liability partnership registered with the Secretary of State pursuant to NRS 87.440 to 87.500, inclusive. (f) A business association. (g) A joint venture, except a joint operating or co-ownership arrangement which meets the requirements of 26 C.F.R. § 1.761-2(a)(3), Treas. Reg. § 1.761-2(a)(3), that elects out of federal partnership treatment as provided by 26 U.S.C. § 761(a). (h) A joint stock company. (i) A holding company. (j) A natural person who is required to file with the Internal Revenue Service a: (1) Schedule C (Form 1040), Profit or Loss from Business, or its equivalent or successor form; (2) Schedule E (Form 1040), Supplemental Income and Loss, or its equivalent or successor form, if an activity of the natural person is reported on Part I of that Schedule; or (3) Schedule F (Form 1040), Profit or Loss from Farming, or its equivalent or successor form. (k) Any other person engaging in a business in this State. 3. For the purpose of determining whether a person or other entity is subject to the commerce tax, a person or other entity is not a business entity if the person or entity is listed in subsection 2 of NRS 363C.020, regardless of whether the person or entity is engaging in a business in this State. 4. As used in this section: (a) “Holding company” means an entity that confines its activities to owning stock in, and supervising management of, other companies.",
          "role": "regulation treating a holding company as a business entity unless listed in NRS 363C.020(2)",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/2708464748661768dc610f088f2ab9534dec9cb09909cbe313c3545f2f18067d.html",
          "source_sha256": "2708464748661768dc610f088f2ab9534dec9cb09909cbe313c3545f2f18067d",
          "source_url": "https://www.leg.state.nv.us/NAC/NAC-363C.html"
        },
        {
          "pinpoint": "Department of Taxation Commerce Tax FAQs, 'Filing Requirement FAQs'",
          "quote": "I have a rental property in Nevada. Am I a subject to the Commerce Tax? Yes. According to Commerce Tax law, rent is NOT passive income.",
          "role": "agency statement that rent is not passive income",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/82ed8aba608dc0de33e87464d98c26e05980b132ec30727108d824f4142c056b.html",
          "source_sha256": "82ed8aba608dc0de33e87464d98c26e05980b132ec30727108d824f4142c056b",
          "source_url": "https://tax.nv.gov/faqs/commerce-tax-faq/"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NRS 363C.020(2)(m) and NRS 363C.093(2)-(3)(a), Chapter 363C; NAC 363C.210(2)-(4)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "2. As used in paragraph (b) of subsection 1, the term “income” does not include any: (a) Rent; or (b) Income received by a nonoperator from mineral properties under a joint operating agreement if the nonoperator is a member of an affiliated group and another member of that group is the operator under that joint operating agreement. 3. For the purposes of paragraph (c) of subsection 1: (a) Except as otherwise provided in this subsection, a business entity is “conducting an active trade or business” if: (1) The activities being carried on by the business entity include one or more active operations that form a part of the process of earning income or profit, and the business entity performs active management and operating functions; or (2) Any assets, including, without limitation, royalties, patents, trademarks and other intangible assets, held by the business entity are used in the active trade or business of one or more related business entities.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-363c-commerce-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7a746cd78156695763513302254569bf53a0a2563789acddf669c58b9f44d0a9",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.does_not_reach.state_business_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Full-text search of NRS ch. 76 (NRS 76.010 to 76.180) and NRS ch. 86; no holding or passive-entity carve-out from the state business license or its fee located",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-076-state-business-license.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9bc5e1d47997aedeb6e8bee704c12617dafeaa7718e79eaee6ed1a33335b8602",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.effective_period.commerce_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NRS ch. 363C (NRS 363C.010 to 363C.700) and NAC ch. 363C (NAC 363C.100 to 363C.590), full text",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-363c-commerce-tax.html",
      "snapshot_resolved": true,
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      "source_sha256": "7a746cd78156695763513302254569bf53a0a2563789acddf669c58b9f44d0a9",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.effective_period.state_business_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "NRS ch. 76 states no effective or sunset date for the state business license or its fee.",
      "fetch_event_id": null,
      "pinpoint": "NRS ch. 76 (NRS 76.010 to 76.180), full text",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-076-state-business-license.html",
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      "source_class": "S1",
      "source_sha256": "9bc5e1d47997aedeb6e8bee704c12617dafeaa7718e79eaee6ed1a33335b8602",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.filing_rule.commerce_tax": {
      "additional_sources": [
        {
          "pinpoint": "Department of Taxation Commerce Tax FAQs, 'Filing Requirement FAQs' and 'Registration FAQs'",
          "quote": "Do exempt entities have to register for Commerce Tax? No. Exempt entities are not required to register for Commerce Tax. The list of exempt entities can be found in Filing Requirements FAQs. Who can file the Exempt Status Entity Form? Exempt entities that have been registered for Commerce Tax and whose Nevada gross revenue exceeds $4,000,000 during the tax year can file the Exempt Status Entity Form",
          "role": "agency guidance on registration and filing by exempt entities",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/82ed8aba608dc0de33e87464d98c26e05980b132ec30727108d824f4142c056b.html",
          "source_sha256": "82ed8aba608dc0de33e87464d98c26e05980b132ec30727108d824f4142c056b",
          "source_url": "https://tax.nv.gov/faqs/commerce-tax-faq/"
        },
        {
          "pinpoint": "Department of Taxation Commerce Tax FAQs, 'Filing Requirement FAQs' (consolidated return question)",
          "quote": "Our Nevada company has subsidiaries in Nevada and in other states. It files a consolidated Federal tax return. Can it file a consolidated tax return for the Commerce Tax? No. Each entity has to determine its own filing requirement and file its own return, if a filing requirement exists.",
          "role": "agency guidance: each entity files its own return",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/82ed8aba608dc0de33e87464d98c26e05980b132ec30727108d824f4142c056b.html",
          "source_sha256": "82ed8aba608dc0de33e87464d98c26e05980b132ec30727108d824f4142c056b",
          "source_url": "https://tax.nv.gov/faqs/commerce-tax-faq/"
        },
        {
          "pinpoint": "Department of Taxation form EXC-F026 'Exempt Status Entity Form', Part 3",
          "quote": "The above entity is exempt from commerce tax filing requirement because it is (see Definitions and check applicable): Governmental entity Non-profit entity organized pursuant IRC § 501(c) or NRS 82 or NRS 84 Credit Union organized under NRS 678 or the Federal Credit Union Act Grantor trust excluding trust taxed as business entity pursuant 26 C.F.R. § 301.7701-4(b) 1 Estate of a natural person excluding estate taxable as a business entity under 26 C.F.R. § 301.7704-4(b) IRC § 856 Real Estate Investment Trust not directly holding real estate 2 3 IRC § 860D Real Estate Mortgage Investment Conduit IRC § 401(a) Trust Passive entity 4 Intangible investments entity",
          "role": "agency form for exempt entities (passive entity; intangible investments entity)",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/6a706b38d44c13316fd1606f624ba4873f6779bd7900a134177836303b20558b.pdf",
          "source_sha256": "6a706b38d44c13316fd1606f624ba4873f6779bd7900a134177836303b20558b",
          "source_url": "https://tax.nv.gov/wp-content/uploads/2024/03/EXC-F026-Exempt-Status-Entity-Form-1.pdf"
        },
        {
          "pinpoint": "Department of Taxation form EXC-F026 'Exempt Status Entity Form', Part 4",
          "quote": "If the entity status changes I will file the commerce tax return for the above entity for the year in which the status change occurs.",
          "role": "certification: return to be filed if status changes",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/6a706b38d44c13316fd1606f624ba4873f6779bd7900a134177836303b20558b.pdf",
          "source_sha256": "6a706b38d44c13316fd1606f624ba4873f6779bd7900a134177836303b20558b",
          "source_url": "https://tax.nv.gov/wp-content/uploads/2024/03/EXC-F026-Exempt-Status-Entity-Form-1.pdf"
        },
        {
          "pinpoint": "Department of Taxation form EXC-F025 Commerce Tax Return, instructions, 'Who Must File'",
          "quote": "Who Must File: Each business entity, whose Nevada gross revenue exceeds $4,000,000 during the taxable year, unless specifically exempted by Commerce Tax law (Nevada Revised Statutes (NRS), Chapter 363C), has to file a Commerce Tax return.",
          "role": "agency return instructions",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/7496390b4d18be197372aa2e5b1eb1b9215bbae1f5bba4494194f0cbc82d4184.pdf",
          "source_sha256": "7496390b4d18be197372aa2e5b1eb1b9215bbae1f5bba4494194f0cbc82d4184",
          "source_url": "https://tax.nv.gov/wp-content/uploads/2025/07/EXC-F025-COM-Tax-Return-2.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NRS 363C.200(2), Chapter 363C, 'Imposition and Collection'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "2. Each business entity whose Nevada gross revenue in a taxable year exceeds $4,000,000 shall, on or before the 45th day immediately following the end of that taxable year, file with the Department a return on a form prescribed by the Department. The Department shall not require a business entity whose Nevada gross revenue for a taxable year is $4,000,000 or less to file a return for that taxable year. The return required by this subsection must include such information as is required by the Department.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-363c-commerce-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7a746cd78156695763513302254569bf53a0a2563789acddf669c58b9f44d0a9",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.filing_rule.state_business_license_fee": {
      "additional_sources": [
        {
          "pinpoint": "NRS 86.263(2) and (3)(a), Chapter 86 Limited-Liability Companies",
          "quote": "2. The limited-liability company shall thereafter, on or before the last day of the month in which the anniversary date of its organization occurs, or, if, pursuant to subsection 12, the limited-liability company has selected an alternative due date for filing the list required by subsection 1, on or before the last day of the month in which the anniversary date of the alternative due date occurs in each year, file with the Secretary of State, on a form furnished by the Secretary of State, an annual list containing all of the information required in subsection 1. 3. Each list required by subsections 1 and 2 must be accompanied by a declaration under penalty of perjury that: (a) The limited-liability company has complied with the provisions of chapter 76 of NRS;",
          "role": "LLC annual list filing and chapter 76 declaration",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-086-llc.html",
          "source_sha256": "d619c4ac81a5a772bd4eb8df6807505bf66920fed2b188eca57d3de7fe81e5db",
          "source_url": "https://www.leg.state.nv.us/NRS/NRS-086.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NRS 76.100(1)(a) and NRS 76.105(1), (5)-(6), Chapter 76; NRS 86.263(2)-(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) An entity required to file an initial or annual list with the Secretary of State pursuant to this title, the person must obtain the state business license at the time of filing the initial or annual list.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-076-state-business-license.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9bc5e1d47997aedeb6e8bee704c12617dafeaa7718e79eaee6ed1a33335b8602",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.tax_regime.commerce_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NRS 363C.200(1), Chapter 363C Commerce Tax, 'Imposition and Collection', section heading 'Imposition; payment of tax; filing of return; extension of time for payment; payment of interest during period of extension.'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "1. For the privilege of engaging in a business in this State, a commerce tax is hereby imposed upon each business entity whose Nevada gross revenue in a taxable year exceeds $4,000,000 in an amount determined pursuant to NRS 363C.300 to 363C.560, inclusive. The commerce tax is due and payable as provided in this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-363c-commerce-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7a746cd78156695763513302254569bf53a0a2563789acddf669c58b9f44d0a9",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.tax_regime.state_business_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NRS 76.100 and NRS 76.130, Chapter 76 State Business Licenses, section headings 'State business license required; application and fee for license; ...' and 'Annual renewal of state business license: Fee; ...'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "1. A person shall not conduct a business in this State unless and until the person obtains a state business license issued by the Secretary of State. If the person is: (a) An entity required to file an initial or annual list with the Secretary of State pursuant to this title, the person must obtain the state business license at the time of filing the initial or annual list. (b) Not an entity required to file an initial or annual list with the Secretary of State pursuant to this title, the person must obtain the state business license before conducting a business in this State.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-076-state-business-license.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9bc5e1d47997aedeb6e8bee704c12617dafeaa7718e79eaee6ed1a33335b8602",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.treatment.commerce_tax": {
      "additional_sources": [
        {
          "pinpoint": "NAC 363C.110",
          "quote": "For the purposes of the exemption from the commerce tax set forth in paragraph (m) of subsection 2 of NRS 363C.020, the term “intangible investments” includes, without limitation, the intangible investments described in that paragraph and an interest in any entity, including, without limitation, a trust, S corporation, partnership, limited-liability company or other entity in which a person owns an interest, regardless of whether that person controls or participates in the management of the entity in which the person owns an interest.",
          "role": "regulation calling NRS 363C.020(2)(m) an exemption from the commerce tax",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/2708464748661768dc610f088f2ab9534dec9cb09909cbe313c3545f2f18067d.html",
          "source_sha256": "2708464748661768dc610f088f2ab9534dec9cb09909cbe313c3545f2f18067d",
          "source_url": "https://www.leg.state.nv.us/NAC/NAC-363C.html"
        },
        {
          "pinpoint": "Department of Taxation Commerce Tax FAQs, 'Filing Requirement FAQs', 'What entities are exempt from Commerce Tax?'",
          "quote": "The list of entities exempt from the Commerce Tax is limited to: Natural person, unless such person is engaged in a business and files Schedule C, E (Part 1) or F with the federal tax return; Governmental entity; Non-profit organization pursuant to section 501(c) of the Internal Revenue Code; Business entity organized pursuant to NRS 82 or NRS 84; Credit union; Grantor trust, excluding a trust taxable as a business entity for federal tax purposes; Estate of a natural person, excluding an estate taxable as a business entity for federal tax purposes; Certain REITs – Real Estate Investment Trusts; REMIC – Real Estate Mortgage Investment Conduit; Trust qualified under section 401(a) of the Internal Revenue Code; Passive Entity; Entity, which only owns and manages intangible investments, such as stocks, bonds, patents, trademarks; Participant in an exhibition NOT required to obtain state business license (NRS 360.780); Any person or entity which is prohibited from taxing pursuant to Constitution or law.",
          "role": "agency list of exempt entities (passive entity; intangible-investment entity)",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/82ed8aba608dc0de33e87464d98c26e05980b132ec30727108d824f4142c056b.html",
          "source_sha256": "82ed8aba608dc0de33e87464d98c26e05980b132ec30727108d824f4142c056b",
          "source_url": "https://tax.nv.gov/faqs/commerce-tax-faq/"
        },
        {
          "pinpoint": "Department of Taxation form EXC-F026 'Exempt Status Entity Form', Part 2 and Part 3",
          "quote": "The above entity is organized or incorporated in Nevada as (check applicable): Association Partnership ✔ Cooperative Sole proprietor Corporation Trust Limited Liability Company Other (specify) Part 3. Exemption reason The above entity is exempt from commerce tax filing requirement because it is (see Definitions and check applicable): Governmental entity Non-profit entity organized pursuant IRC § 501(c) or NRS 82 or NRS 84 Credit Union organized under NRS 678 or the Federal Credit Union Act Grantor trust excluding trust taxed as business entity pursuant 26 C.F.R. § 301.7701-4(b) 1 Estate of a natural person excluding estate taxable as a business entity under 26 C.F.R. § 301.7704-4(b) IRC § 856 Real Estate Investment Trust not directly holding real estate 2 3 IRC § 860D Real Estate Mortgage Investment Conduit IRC § 401(a) Trust Passive entity 4 Intangible investments entity",
          "role": "agency form listing limited liability company as an entity type that may claim the passive-entity or intangible-investments exemption",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/c50/NV/6a706b38d44c13316fd1606f624ba4873f6779bd7900a134177836303b20558b.pdf",
          "source_sha256": "6a706b38d44c13316fd1606f624ba4873f6779bd7900a134177836303b20558b",
          "source_url": "https://tax.nv.gov/wp-content/uploads/2024/03/EXC-F026-Exempt-Status-Entity-Form-1.pdf"
        },
        {
          "pinpoint": "NRS 0.039, Preliminary Chapter (NRS ch. 0), section heading 'Person defined.'",
          "quote": "Except as otherwise expressly provided in a particular statute or required by the context, “person” means a natural person, any form of business or social organization and any other nongovernmental legal entity including, but not limited to, a corporation, partnership, association, trust or unincorporated organization. The term does not include a government, governmental agency or political subdivision of a government.",
          "role": "general NRS definition of 'person', the word used in NRS 363C.020(2)(m)",
          "snapshot_path": "rigs/entity-research/structuring/discovery/NV/snapshots/nv-nrs-ch0-general-definitions.html",
          "source_sha256": "b4ccde5faa476339bf2ae094cd14b94e37b22eef0875fb9997f6bb93fc4887e6",
          "source_url": "https://www.leg.state.nv.us/NRS/NRS-000.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NRS 363C.200(1); NRS 363C.020(2)(l)-(m); NRS 363C.093(1)(a), Chapter 363C",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "2. “Business entity” does not include: […] (l) A passive entity.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-363c-commerce-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7a746cd78156695763513302254569bf53a0a2563789acddf669c58b9f44d0a9",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NV.llc.treatment.state_business_license_fee": {
      "additional_sources": [
        {
          "pinpoint": "NRS 86.263(3)(a) and NRS 86.5461(2)(a), Chapter 86 Limited-Liability Companies",
          "quote": "3. Each list required by subsections 1 and 2 must be accompanied by a declaration under penalty of perjury that: (a) The limited-liability company has complied with the provisions of chapter 76 of NRS; […] 2. Each list filed pursuant to this section must be accompanied by a declaration under penalty of perjury that: (a) The foreign limited-liability company has complied with the provisions of chapter 76 of NRS;",
          "role": "LLC act applying chapter 76 to domestic and foreign LLCs",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-086-llc.html",
          "source_sha256": "d619c4ac81a5a772bd4eb8df6807505bf66920fed2b188eca57d3de7fe81e5db",
          "source_url": "https://www.leg.state.nv.us/NRS/NRS-086.html"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "NRS 76.020(1)(c), NRS 76.100(1) and (7)(a), NRS 76.130(6), Chapter 76; NRS 86.263(3)(a), 86.5461(2)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Any entity organized pursuant to this title, including, without limitation, those entities required to file with the Secretary of State, whether or not the entity performs a service or engages in a business for profit.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NV/snapshots/nv-code-076-state-business-license.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9bc5e1d47997aedeb6e8bee704c12617dafeaa7718e79eaee6ed1a33335b8602",
      "source_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.base_tax_locator.annual_llc_filing_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The LLC filing-fee measure and schedule are located in N.Y. Tax Law §658(c)(3)(A)-(B).",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §658(c)(3)(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(B) The filing fee will be based on the New York source gross income of the limited liability company or partnership for the taxable year immediately preceding the taxable year for which the fee is due. If the limited liability company or partnership does not have any New York source gross income for the taxable year immediately preceding the taxable year for which the fee is due, the limited liability company or partnership shall pay the minimum filing fee. Partnerships, other than limited liability partnerships under article eight-B of the partnership law and foreign limited liability partnerships, with less than one million dollars in New York source gross income are exempt from the filing fee. New York source gross income is the sum of the partners' or members' shares of federal gross income from the partnership or limited liability company derived from or connected with New York sources, determined in accordance with the provisions of section six hundred thirty-one of this article as if those provisions and any related provisions expressly referred to a computation of federal gross income from New York sources. For this purpose, federal gross income is computed without any allowance or deduction for cost of goods sold. The amount of the filing fee for taxable years beginning on or after January first, two thousand eight will be determined in accordance with the following table: If the New York source gross income is: The fee is: not more than $100,000 $25 more than $100,000 but not over $250,000 $50 more than $250,000 but not over $500,000 $175 more than $500,000 but not over $1,000,000 $500 more than $1,000,000 but not over $5,000,000 $1,500 more than $5,000,000 but not over $25,000,000 $3,000 Over $25,000,000 $4,500",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.base_tax_locator.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "N.Y. Tax Law §210(1)(a)",
          "quote": "(a) Business income base. For taxable years beginning before January first, two thousand sixteen, the amount prescribed by this paragraph shall be computed at the rate of seven and one-tenth percent of the taxpayer's business income base. For taxable years beginning on or after January first, two thousand sixteen, the amount prescribed by this paragraph shall be six and one-half percent of the taxpayer's business income base. For taxable years beginning on or after January first, two thousand twenty-one and before January first, two thousand thirty for any taxpayer with a business income base for the taxable year of more than five million dollars, the amount prescribed by this paragraph shall be seven and one-quarter percent of the taxpayer's business income base. The taxpayer's business income base shall mean the portion of the taxpayer's business income apportioned within the state as hereinafter provided. However, in the case of a small business taxpayer, as defined in paragraph (f) of this subdivision, the amount prescribed by this paragraph shall be computed pursuant to subparagraph (iv) of this paragraph and in the case of a manufacturer, as defined in subparagraph (vi) of this paragraph, the amount prescribed by this paragraph shall be computed pursuant to subparagraph (vi) of this paragraph, and, in the case of a qualified emerging technology company, as defined in subparagraph (vii) of this paragraph, the amount prescribed by this paragraph shall be computed pursuant to subparagraph (vii) of this paragraph.",
          "role": "supporting",
          "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/2e003c23359803f66c1b993f9546143a9f0770d4c8bac552634a94807a59b12a.html",
          "source_sha256": "2e003c23359803f66c1b993f9546143a9f0770d4c8bac552634a94807a59b12a",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/210"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The Article 9-A computation bases are located in N.Y. Tax Law §210(1).",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §210(1), introductory computation rule",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "§ 210. Computation of tax. 1. The tax imposed by subdivision one of section two hundred nine of this chapter shall be: (A) in the case of each taxpayer other than a New York S corporation or a qualified homeowners association, the highest of the amounts prescribed in paragraphs (a), (b), and (d) of this subdivision, (B) in the case of each New York S corporation, the amount prescribed in paragraph (d) of this subdivision, and (C) in the case of a qualified homeowners association, the highest of the amounts prescribed in paragraphs (a) and (b) of this subdivision. For purposes of this paragraph, the term \"qualified homeowners association\" means a homeowners association, as such term is defined in subsection (c) of section five hundred twenty-eight of the internal revenue code without regard to subparagraph (E) of paragraph one of such subsection (relating to elections to be taxed pursuant to such section), which has no homeowners association taxable income, as such term is defined in subsection (d) of such section. Provided, however, that in the case of a small business taxpayer (other than a New York S corporation) as defined in paragraph (f) of this subdivision, for taxable years beginning before January first, two thousand sixteen, if the amount prescribed in such paragraph (b) is higher than the amount prescribed in such paragraph (a) solely by reason of the application of the rate applicable to small business taxpayers, then with respect to such taxpayer the tax referred to in the previous sentence shall be higher of the amounts prescribed in paragraphs (a) and (d) of this subdivision.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/2e003c23359803f66c1b993f9546143a9f0770d4c8bac552634a94807a59b12a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2e003c23359803f66c1b993f9546143a9f0770d4c8bac552634a94807a59b12a",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/210",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The Article 24-A pass-through entity tax rate table is located in N.Y. Tax Law §862.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §862",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "§ 862. Imposition and rate of tax. A tax is hereby imposed for each taxable year on the pass-through entity taxable income of every electing partnership and every electing S corporation. This tax shall be in addition to any other taxes imposed under this chapter and shall be determined in accordance with the following table: For each taxable year beginning on or after January first, two thousand twenty-one: If pass-through entity taxable income is: Not over $2,000,000 6.85% of taxable income. Over $2,000,000 but not over $5,000,000 $137,000 plus 9.65% of the excess over $2,000,000. Over $5,000,000 but not over $25,000,000 $426,500 plus 10.30% of excess over $5,000,000. Over $25,000,000 $2,486,500 plus 10.90% of the excess over $25,000,000.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/16a561e6eefec073b105ace3e18f5d485819dc867e9296c2fe7d926285606a4b.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "16a561e6eefec073b105ace3e18f5d485819dc867e9296c2fe7d926285606a4b",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/862",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.does_not_reach.annual_llc_filing_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §658(c)(3)(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(B) The filing fee will be based on the New York source gross income of the limited liability company or partnership for the taxable year immediately preceding the taxable year for which the fee is due. If the limited liability company or partnership does not have any New York source gross income for the taxable year immediately preceding the taxable year for which the fee is due, the limited liability company or partnership shall pay the minimum filing fee. Partnerships, other than limited liability partnerships under article eight-B of the partnership law and foreign limited liability partnerships, with less than one million dollars in New York source gross income are exempt from the filing fee. New York source gross income is the sum of the partners' or members' shares of federal gross income from the partnership or limited liability company derived from or connected with New York sources, determined in accordance with the provisions of section six hundred thirty-one of this article as if those provisions and any related provisions expressly referred to a computation of federal gross income from New York sources. For this purpose, federal gross income is computed without any allowance or deduction for cost of goods sold. The amount of the filing fee for taxable years beginning on or after January first, two thousand eight will be determined in accordance with the following table: If the New York source gross income is: The fee is: not more than $100,000 $25 more than $100,000 but not over $250,000 $50 more than $250,000 but not over $500,000 $175 more than $500,000 but not over $1,000,000 $500 more than $1,000,000 but not over $5,000,000 $1,500 more than $5,000,000 but not over $25,000,000 $3,000 Over $25,000,000 $4,500",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.does_not_reach.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §208(5)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "5. (a) The term \"investment capital\" means investments in stocks that (i) satisfy the definition of a capital asset under section 1221 of the internal revenue code at all times the taxpayer owned such stock during the taxable year, (ii) are held by the taxpayer for investment for more than one year, (iii) the dispositions of which are, or would be, treated by the taxpayer as generating long-term capital gains or losses under the internal revenue code, (iv) for stocks acquired on or after January first, two thousand fifteen, at any time after the close of the day in which they are acquired, have never been held for sale to customers in the regular course of business, and (v) before the close of the day on which the stock was acquired, are clearly identified in the taxpayer's records as stock held for investment in the same manner as required under section 1236(a)(1) of the internal revenue code for the stock of a dealer in securities to be eligible for capital gain treatment (whether or not the taxpayer is a dealer of securities subject to section 1236), provided, however, that for stock acquired prior to October first, two thousand fifteen that was not subject to section 1236(a) of the internal revenue code, such identification in the taxpayer's records must occur before October first, two thousand fifteen. Stock in a corporation that is conducting a unitary business with the taxpayer, stock in a corporation that is included in a combined report with the taxpayer pursuant to the commonly owned group election in subdivision three of section two hundred ten-C of this article, and stock issued by the taxpayer shall not constitute investment capital. For purposes of this subdivision, if the taxpayer owns or controls, directly or indirectly, less than twenty percent of the voting power of the stock of a corporation, that corporation will be presumed to be conducting a business that is not unitary with the business of the taxpayer.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/c4a8ee8e9838da317cf971d34587e5fb755ffbc8e5e124707ca06ac9d5a09c0d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "c4a8ee8e9838da317cf971d34587e5fb755ffbc8e5e124707ca06ac9d5a09c0d",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/208",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §860(a)-(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Eligible partnership. Eligible partnership means any partnership as provided for in section 7701(a)(2) of the Internal Revenue Code that has a filing requirement under paragraph one of subsection (c) of section six hundred fifty-eight of this chapter other than a publicly traded partnership as defined in section 7704 of the Internal Revenue Code. An eligible partnership includes any entity, including a limited liability company, treated as a partnership for federal income tax purposes that otherwise meets the requirements of this subdivision. (b) Eligible S corporation. Eligible S corporation means any New York S corporation as defined pursuant to subdivision one-A of section two hundred eight of this chapter that is subject to tax under section two hundred nine of this chapter. An eligible S corporation includes any entity, including a limited liability company, treated as an S corporation for federal income tax purposes that otherwise meets the requirements of this subdivision.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/73b285b1152af63454bf2bac79ab306837112d5c35cfecef2f2cfc74fe72b881.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "73b285b1152af63454bf2bac79ab306837112d5c35cfecef2f2cfc74fe72b881",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/860",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.effective_period.annual_llc_filing_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The provision states that the current minimum and disregarded-LLC filing fee apply for taxable years beginning in 2008 and thereafter.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §658(c)(3)(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The minimum filing fee is twenty-five dollars for taxable years beginning in two thousand eight and thereafter. Limited liability companies that are disregarded entities for federal income tax purposes must pay a filing fee of twenty-five dollars for taxable years beginning on or after January first, two thousand eight.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.effective_period.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §210(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Business income base. For taxable years beginning before January first, two thousand sixteen, the amount prescribed by this paragraph shall be computed at the rate of seven and one-tenth percent of the taxpayer's business income base. For taxable years beginning on or after January first, two thousand sixteen, the amount prescribed by this paragraph shall be six and one-half percent of the taxpayer's business income base. For taxable years beginning on or after January first, two thousand twenty-one and before January first, two thousand thirty for any taxpayer with a business income base for the taxable year of more than five million dollars, the amount prescribed by this paragraph shall be seven and one-quarter percent of the taxpayer's business income base. The taxpayer's business income base shall mean the portion of the taxpayer's business income apportioned within the state as hereinafter provided. However, in the case of a small business taxpayer, as defined in paragraph (f) of this subdivision, the amount prescribed by this paragraph shall be computed pursuant to subparagraph (iv) of this paragraph and in the case of a manufacturer, as defined in subparagraph (vi) of this paragraph, the amount prescribed by this paragraph shall be computed pursuant to subparagraph (vi) of this paragraph, and, in the case of a qualified emerging technology company, as defined in subparagraph (vii) of this paragraph, the amount prescribed by this paragraph shall be computed pursuant to subparagraph (vii) of this paragraph.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/2e003c23359803f66c1b993f9546143a9f0770d4c8bac552634a94807a59b12a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2e003c23359803f66c1b993f9546143a9f0770d4c8bac552634a94807a59b12a",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/210",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §861(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) The annual election must be made on or before the due date of the first estimated payment under section eight hundred sixty-four of this article and will take effect for the current taxable year. Only one election may be made during each calendar year. An election made under this section is irrevocable after the due date.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/a2c01bd9d50e5317ef103a8d0f8ff28256c24022e70fcdfaba3c1747da34b682.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a2c01bd9d50e5317ef103a8d0f8ff28256c24022e70fcdfaba3c1747da34b682",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/861",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.filing_rule.annual_llc_filing_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The filing-fee payment is due by the fifteenth day of the third month following the close of the taxable year.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §658(c)(3)(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) Filing fees. (A) Every subchapter K limited liability company, every limited liability company that is a disregarded entity for federal income tax purposes, and every partnership which has any income derived from New York sources, determined in accordance with the applicable rules of section six hundred thirty-one of this article as in the case of a nonresident individual, shall on or before the fifteenth day of the third month following the close of each taxable year make a payment of a filing fee. The amount of the filing fee is the amount set forth in subparagraph (B) of this paragraph. The minimum filing fee is twenty-five dollars for taxable years beginning in two thousand eight and thereafter. Limited liability companies that are disregarded entities for federal income tax purposes must pay a filing fee of twenty-five dollars for taxable years beginning on or after January first, two thousand eight.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.filing_rule.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §211(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "1. Every taxpayer shall annually on or before March fifteenth, for taxable years beginning before January first, two thousand sixteen, and annually on or before April fifteenth, for taxable years beginning on or after January first, two thousand sixteen, transmit to the commissioner a report in a form prescribed by the commissioner (except that a corporation which reports on the basis of a fiscal year shall transmit its report within two and one-half months after the close of its fiscal year, for taxable years beginning before January first, two thousand sixteen, and on or before the fifteenth day of the fourth month after the close of its fiscal year, for taxable years beginning on or after January first, two thousand sixteen, and except, also, that a corporation which is a DISC shall transmit its report on or before the fifteenth day of the ninth month following the close of its calendar or fiscal year), setting forth such information as the commissioner may prescribe and every taxpayer which ceases to exercise its franchise or to be subject to the tax imposed by this article shall transmit to the commissioner a report on the date of such cessation or at such other time as the commissioner may require covering each year or period for which no report was theretofore filed. In the case of a termination year of an S corporation, the S short year and the C short year shall be treated as separate short taxable years, provided, however, the due date of the report for the S short year shall be the same as the due date of the report for the C short year. Every taxpayer shall also transmit such other reports and such facts and information as the commissioner may require in the administration of this article. The commissioner may grant a reasonable extension of time for filing reports whenever good cause exists.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/04113b8d8f70ca47fdc7332a4ac3489422a12aa9b40f69750fd5321f10a1c94e.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "04113b8d8f70ca47fdc7332a4ac3489422a12aa9b40f69750fd5321f10a1c94e",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/211",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "N.Y. Tax Law §861(a)-(c)",
          "quote": "(a) Any eligible partnership or eligible S corporation shall be allowed to make an annual election to be taxed pursuant to this article. (b) In order to be effective, the annual election must be made (1) if the entity is an S corporation, by any officer, manager or shareholder of the S corporation who is authorized under the law of the state where the corporation is incorporated or under the S corporation's organizational documents to make the election and who represents to having such authorization under penalty of perjury; or (2) if the entity is not an S corporation, by any member, partner, owner, or other individual with authority to bind the entity or sign returns pursuant to section six hundred fifty-three of this chapter. (c) The annual election must be made on or before the due date of the first estimated payment under section eight hundred sixty-four of this article and will take effect for the current taxable year. Only one election may be made during each calendar year. An election made under this section is irrevocable after the due date.",
          "role": "supporting",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/a2c01bd9d50e5317ef103a8d0f8ff28256c24022e70fcdfaba3c1747da34b682.html",
          "source_sha256": "a2c01bd9d50e5317ef103a8d0f8ff28256c24022e70fcdfaba3c1747da34b682",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/861"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Each electing partnership and electing S corporation must file its Article 24-A return by March fifteenth following the close of the stated year.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §865(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) General. On or before March fifteenth following the close of the taxable year, each electing partnership and each electing S corporation must file a return for the taxable year reporting the information required pursuant to this article. For each electing partnership and each electing S corporation that has a fiscal taxable year, the return is due on or before March fifteenth following the close of the calendar year that contains the final day of the entity's taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/40daf7dcdea16428b28b75d07e54693c962238da86558a79d87aa02a702c80d5.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "40daf7dcdea16428b28b75d07e54693c962238da86558a79d87aa02a702c80d5",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/865",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.tax_regime.annual_llc_filing_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §658(c)(3)(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) Filing fees. (A) Every subchapter K limited liability company, every limited liability company that is a disregarded entity for federal income tax purposes, and every partnership which has any income derived from New York sources, determined in accordance with the applicable rules of section six hundred thirty-one of this article as in the case of a nonresident individual, shall on or before the fifteenth day of the third month following the close of each taxable year make a payment of a filing fee. The amount of the filing fee is the amount set forth in subparagraph (B) of this paragraph. The minimum filing fee is twenty-five dollars for taxable years beginning in two thousand eight and thereafter. Limited liability companies that are disregarded entities for federal income tax purposes must pay a filing fee of twenty-five dollars for taxable years beginning on or after January first, two thousand eight.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.tax_regime.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §209(1)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) For the privilege of exercising its corporate franchise, or of doing business, or of employing capital, or of owning or leasing property in this state in a corporate or organized capacity, or of maintaining an office in this state, or of deriving receipts from activity in this state, for all or any part of each of its fiscal or calendar years, every domestic or foreign corporation, except corporations specified in subdivision four of this section, shall annually pay a franchise tax, upon the basis of its business income base, or upon such other basis as may be applicable as hereinafter provided, for such fiscal or calendar year or part thereof, on a report which shall be filed, except as hereinafter provided, on or before the fifteenth day of March next succeeding the close of each such year, for taxable years beginning before January first, two thousand sixteen, and on or before the fifteenth day of April next succeeding the close of each such year, for taxable years beginning on or after January first, two thousand sixteen, or, in the case of a corporation which reports on the basis of a fiscal year, within two and one-half months after the close of such fiscal year, for taxable years beginning before January first, two thousand sixteen, and on or before the fifteenth day of the fourth month after the close of such fiscal year, for taxable years beginning on or after January first, two thousand sixteen, and shall be paid as hereinafter provided.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/ny-stat-tax-209.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "219bcfd9505fbb3c1ada53e088616aaaadd63ae418f532cff6780d15f7dcc8e6",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/209",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Article 24-A imposes tax for each taxable year on the pass-through entity taxable income of every electing partnership and electing S corporation.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §862",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "§ 862. Imposition and rate of tax. A tax is hereby imposed for each taxable year on the pass-through entity taxable income of every electing partnership and every electing S corporation. This tax shall be in addition to any other taxes imposed under this chapter and shall be determined in accordance with the following table: For each taxable year beginning on or after January first, two thousand twenty-one: If pass-through entity taxable income is: Not over $2,000,000 6.85% of taxable income. Over $2,000,000 but not over $5,000,000 $137,000 plus 9.65% of the excess over $2,000,000. Over $5,000,000 but not over $25,000,000 $426,500 plus 10.30% of excess over $5,000,000. Over $25,000,000 $2,486,500 plus 10.90% of the excess over $25,000,000.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/16a561e6eefec073b105ace3e18f5d485819dc867e9296c2fe7d926285606a4b.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "16a561e6eefec073b105ace3e18f5d485819dc867e9296c2fe7d926285606a4b",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/862",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#NY.llc.treatment.annual_llc_filing_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §658(c)(3)(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(3) Filing fees. (A) Every subchapter K limited liability company, every limited liability company that is a disregarded entity for federal income tax purposes, and every partnership which has any income derived from New York sources, determined in accordance with the applicable rules of section six hundred thirty-one of this article as in the case of a nonresident individual, shall on or before the fifteenth day of the third month following the close of each taxable year make a payment of a filing fee. The amount of the filing fee is the amount set forth in subparagraph (B) of this paragraph. The minimum filing fee is twenty-five dollars for taxable years beginning in two thousand eight and thereafter. Limited liability companies that are disregarded entities for federal income tax purposes must pay a filing fee of twenty-five dollars for taxable years beginning on or after January first, two thousand eight.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/NY/79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "79acb08deed3a3d0ee7596faf5b9a5bf20ef6b179ab474d5062c2141459a2d3f",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.treatment.corporate_franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "N.Y. Tax Law §208(6)(a)-(c)",
          "quote": "6. (a) (i) The term \"investment income\" means income, including capital gains in excess of capital losses, from investment capital, to the extent included in computing entire net income, less, in the discretion of the commissioner, any interest deductions allowable in computing entire net income which are directly or indirectly attributable to investment capital or investment income, provided, however, that in no case shall investment income exceed entire net income. (ii) If the amount of interest deductions subtracted under subparagraph (i) of this paragraph exceeds investment income, the excess of such amount over investment income must be added back to entire net income. (iii) If the taxpayer's investment income determined without regard to the interest deductions subtracted under subparagraph (i) of this paragraph comprises more than eight percent of the taxpayer's entire net income, investment income determined without regard to such interest deductions cannot exceed eight percent of the taxpayer's entire net income. (b) In lieu of subtracting from investment income the amount of those interest deductions, the taxpayer may make a revocable election to reduce its total investment income, determined after applying the limitation in subparagraph (iii) of paragraph (a) of this subdivision, by forty percent. If the taxpayer makes this election, the taxpayer must also make the elections provided for in paragraphs (b) and (c) of subdivision six-a of this section. If the taxpayer subsequently revokes this election, the taxpayer must revoke the elections provided for in paragraphs (b) and (c) of subdivision six-a of this section. A taxpayer that does not make this election because it has no investment capital will not be precluded from making those other elections. (c) Investment income shall not include any amount treated as dividends pursuant to section seventy-eight of the internal revenue code.",
          "role": "supporting",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/c4a8ee8e9838da317cf971d34587e5fb755ffbc8e5e124707ca06ac9d5a09c0d.html",
          "source_sha256": "c4a8ee8e9838da317cf971d34587e5fb755ffbc8e5e124707ca06ac9d5a09c0d",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/208"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §208(8)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "8. The term \"business income\" means entire net income minus investment income and other exempt income. In no event shall the sum of investment income and other exempt income exceed entire net income. If the taxpayer makes the election provided for in subparagraph one of paragraph (a) of subdivision five of section two hundred ten-A of this article, then all income from qualified financial instruments shall constitute business income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/c4a8ee8e9838da317cf971d34587e5fb755ffbc8e5e124707ca06ac9d5a09c0d.html",
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      "source_class": "S1",
      "source_sha256": "c4a8ee8e9838da317cf971d34587e5fb755ffbc8e5e124707ca06ac9d5a09c0d",
      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/208",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#NY.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "N.Y. Tax Law §861, complete section",
          "quote": "§ 861. Pass-through entity tax election. (a) Any eligible partnership or eligible S corporation shall be allowed to make an annual election to be taxed pursuant to this article. (b) In order to be effective, the annual election must be made (1) if the entity is an S corporation, by any officer, manager or shareholder of the S corporation who is authorized under the law of the state where the corporation is incorporated or under the S corporation's organizational documents to make the election and who represents to having such authorization under penalty of perjury; or (2) if the entity is not an S corporation, by any member, partner, owner, or other individual with authority to bind the entity or sign returns pursuant to section six hundred fifty-three of this chapter. (c) The annual election must be made on or before the due date of the first estimated payment under section eight hundred sixty-four of this article and will take effect for the current taxable year. Only one election may be made during each calendar year. An election made under this section is irrevocable after the due date. (d) Special rules for electing S corporations. (1) An electing S corporation must certify at the time of its election that all shareholders are residents of New York for purposes of article twenty-two of this chapter to be considered an electing resident S corporation. (2) If an electing S corporation does not make a certification under paragraph one of this subsection at the time of its election, the electing S corporation is automatically treated as an electing standard S corporation. (3) If an electing S corporation makes a certification under paragraph one of this subsection to be an electing resident S corporation, this certification is irrevocable as of the due date of the election.",
          "role": "complete_article_search",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/a2c01bd9d50e5317ef103a8d0f8ff28256c24022e70fcdfaba3c1747da34b682.html",
          "source_sha256": "a2c01bd9d50e5317ef103a8d0f8ff28256c24022e70fcdfaba3c1747da34b682",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/861"
        },
        {
          "pinpoint": "N.Y. Tax Law §862, complete section",
          "quote": "§ 862. Imposition and rate of tax. A tax is hereby imposed for each taxable year on the pass-through entity taxable income of every electing partnership and every electing S corporation. This tax shall be in addition to any other taxes imposed under this chapter and shall be determined in accordance with the following table: For each taxable year beginning on or after January first, two thousand twenty-one: If pass-through entity taxable income is: Not over $2,000,000 6.85% of taxable income. Over $2,000,000 but not over $5,000,000 $137,000 plus 9.65% of the excess over $2,000,000. Over $5,000,000 but not over $25,000,000 $426,500 plus 10.30% of excess over $5,000,000. Over $25,000,000 $2,486,500 plus 10.90% of the excess over $25,000,000.",
          "role": "complete_article_search",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/16a561e6eefec073b105ace3e18f5d485819dc867e9296c2fe7d926285606a4b.html",
          "source_sha256": "16a561e6eefec073b105ace3e18f5d485819dc867e9296c2fe7d926285606a4b",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/862"
        },
        {
          "pinpoint": "N.Y. Tax Law §863, complete section",
          "quote": "§ 863. Pass-through entity tax credit. (a) Personal income tax credit. (1) A taxpayer subject to tax under article twenty-two of this chapter that is a direct partner or member in an electing partnership or a direct shareholder of an electing S corporation subject to tax under this article shall be allowed a credit against the tax imposed pursuant to article twenty-two of this chapter, computed pursuant to the provisions of subsection (kkk) of section six hundred six of this chapter. An entity that is disregarded for tax purposes will be disregarded for purposes of determining if a taxpayer is a direct partner or member of an electing partnership or direct shareholder of an electing S corporation. (2) Limitation on credit. No credit shall be allowed to a taxpayer under paragraph one of this subsection unless the electing partnership or electing S corporation paid the tax imposed under this article and provided sufficient information on the pass-through entity tax return as prescribed by the commissioner to identify that taxpayer. Such information shall include, but not be limited to, the social security number or taxpayer identification number of the article twenty-two taxpayer who will claim the credit (even in the case of a disregarded entity owned by such taxpayer). (b) Limitation on credit. The aggregate amount of credits claimed by all partners, members or shareholders of an electing partnership or electing S corporation pursuant to subsection (a) of this section shall not exceed the tax due under subsection (a) of section eight hundred sixty-two of this article from such electing partnership or electing S corporation for the taxable year.",
          "role": "complete_article_search",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/32d8ef9f53c6b4867a118b385c3a7aad266ae4f95b09e163fb83e30fd2d1178a.html",
          "source_sha256": "32d8ef9f53c6b4867a118b385c3a7aad266ae4f95b09e163fb83e30fd2d1178a",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/863"
        },
        {
          "pinpoint": "N.Y. Tax Law §864, complete section",
          "quote": "§ 864. Payment of estimated tax. (a) Definition of estimated tax. Estimated tax means the amount that an electing partnership or electing S corporation estimates to be the tax imposed by section eight hundred sixty-two of this article for the current taxable year. (b) General. The estimated tax shall be paid as follows for an electing partnership and an electing S corporation: (1) The estimated tax shall be paid in four equal installments on March fifteenth, June fifteenth, September fifteenth and December fifteenth in the calendar year prior to the year in which the due date of the return required by this article falls. (2) The amount of any required installment shall be twenty-five percent of the required annual payment. (3) Notwithstanding paragraph four of subsection (c) of section six hundred eighty-five of this chapter, the required annual payment is the lesser of: (A) ninety percent of the tax shown on the return for the taxable year; or (B) one hundred percent of the tax shown on the return of the electing partnership or electing S corporation for the preceding taxable year. (c) Application to short taxable year. This section shall apply to a taxable year of less than twelve months in accordance with procedures established by the commissioner. (d) Installments paid in advance. An electing partnership or electing S corporation may elect to pay any installment of its estimated tax prior to the date prescribed for the payment thereof.",
          "role": "complete_article_search",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/0ec97a8232e0582aa5ce630a52de9bfb1de574a0bb0a558853828a70b9c6f1a0.html",
          "source_sha256": "0ec97a8232e0582aa5ce630a52de9bfb1de574a0bb0a558853828a70b9c6f1a0",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/864"
        },
        {
          "pinpoint": "N.Y. Tax Law §865, complete section",
          "quote": "§ 865. Filing of return and payment of tax. (a) General. On or before March fifteenth following the close of the taxable year, each electing partnership and each electing S corporation must file a return for the taxable year reporting the information required pursuant to this article. For each electing partnership and each electing S corporation that has a fiscal taxable year, the return is due on or before March fifteenth following the close of the calendar year that contains the final day of the entity's taxable year. (b) Certification of eligibility. Every return filed pursuant to subsection (a) of this section shall include, in a format as prescribed by the commissioner, a certification by an individual authorized to act on behalf of the electing partnership or electing S corporation that the taxpayer: (1) made a timely, valid election to be subject to tax pursuant to this article; and (2) that all statements contained therein are true. (c) Information on the electing partnership return. Each electing partnership shall report on such return: (1) Any tax due pursuant to this article. The balance of any tax shown on such return, not previously paid as installments of estimated tax, shall be paid with such return; (2) Identifying information of all partners and/or members eligible to receive a credit pursuant to section eight hundred sixty-three of this article; (3) Each partner's and/or member's share of the pass-through entity tax imposed on the electing partnership; (4) Each partner's and/or member's distributive share of the pass-through entity taxable income calculated pursuant to paragraph one of subsection (h) of section eight hundred sixty of this article; (5) The classification of each partner and/or member as a resident or nonresident for purposes of calculating the electing partnership's pass-through entity taxable income under paragraph one of subsection (h) of section eight hundred sixty of this article; and (6) Any other information as required by the commissioner. (d) Information on electing S corporation return. Each electing S corporation shall report on such return: (1) Any tax due pursuant to this article. The balance of any tax shown on such return, not previously paid as installments of estimated tax, shall be paid with such return; (2) Identifying information of all shareholders eligible to receive a credit pursuant to section eight hundred sixty-three of this article; (3) Each shareholder's direct share of the pass-through entity tax imposed on the electing S corporation; and (4) Any other information as required by the commissioner. (e) Special rules for partners, members and shareholders that are disregarded entities. To meet the requirements of paragraph two of subsection (c) of this section for an electing partnership or paragraph two of subsection (d) of this section for an electing S corporation, the electing partnership or electing S corporation must provide information sufficient to identify both the disregarded entity that is a partner, member and/or shareholder and the taxpayer subject to tax under article twenty-two of this chapter eligible for a credit under subsection (a) of section eight hundred sixty-three of this article. (f) Extensions and amendments. (1) The commissioner may grant a reasonable extension of time for payment of tax or estimated tax (or any installment), or for filing any return, statement, or other document required pursuant to this article, on such terms and conditions as it may require. No such extension for filing any return, statement or other document, shall exceed six months. (2) No amended returns. Once a return has been filed by an electing partnership or electing S corporation, it may not be amended without the consent of or otherwise authorized by the commissioner. (g) Information provided to partners. Each electing partnership subject to tax under this article shall report to each partner or member its: (1) classification as a resident or nonresident for purposes of calculating the electing partnership's or electing S corporation's pass-through entity taxable income under subsection (g) of section eight hundred sixty of this article; (2) direct share of the pass-through entity tax imposed on the electing partnership; and (3) any other information as required by the commissioner.",
          "role": "complete_article_search",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/NY/snapshots/c50/NY/40daf7dcdea16428b28b75d07e54693c962238da86558a79d87aa02a702c80d5.html",
          "source_sha256": "40daf7dcdea16428b28b75d07e54693c962238da86558a79d87aa02a702c80d5",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/865"
        },
        {
          "pinpoint": "N.Y. Tax Law §866, complete section",
          "quote": "§ 866. Procedural provisions. (a) General. All provisions of article twenty-two of this chapter will apply to the provisions of this article in the same manner and with the same force and effect as if the language of article twenty-two of this chapter had been incorporated in full into this article and had been specifically adjusted for and expressly referred to the tax imposed by this article, except to the extent that any provision is either inconsistent with a provision of this article or is not relevant to this article. Notwithstanding the preceding sentence, no credit against tax in article twenty-two of this chapter can be used to offset the tax due pursuant to this article. (b) Notwithstanding any other law to the contrary, the commissioner may require that all forms or returns pursuant to this article must be filed electronically and all payments of tax must be paid electronically. (c) Liability for tax. (1) An electing partnership or electing S corporation shall be liable for the tax due pursuant to this article. (2) Except as provided in paragraph three of this subsection, any article twenty-two taxpayer eligible to claim a credit pursuant to subsection (kkk) of section six hundred six of this chapter because he or she is a partner or member in an electing partnership or a shareholder in an electing S corporation, either directly or through a disregarded entity, shall be severally liable to the extent not paid by the electing partnership or electing S corporation for his or her direct share of pass-through entity tax. (3) Any article twenty-two taxpayer eligible to claim a credit pursuant to subsection (kkk) of section six hundred six of this chapter because he or she is a partner or member in an electing partnership or a shareholder in an electing S corporation, either directly or through a disregarded entity, that is a general, managing or controlling partner of the electing partnership or managing or controlling shareholder of the electing S corporation, or owns greater than fifty percent of the interests or profits of the electing partnership or electing S corporation, or is under a duty to act for the electing partnership or S corporation in complying with the provisions of this article, or was the individual that made the election on behalf of the electing partnership or electing S corporation under subsection (b) of section eight hundred sixty-one of this article shall be jointly and severally liable for the tax imposed pursuant to this article on such electing partnership or electing S corporation. (d) Deposit and disposition of revenue. All taxes, interest, penalties, and fees collected or received by the commissioner pursuant to this article shall be deposited and disposed of pursuant to the provisions of section one hundred seventy-one-a of this chapter. (e) Secrecy provision. All the provisions of paragraphs one and two of subsection (e) of section six hundred ninety-seven of this chapter will apply to the provisions of this article. Notwithstanding any provisions of this chapter to the contrary, the commissioner may disclose information and returns regarding the calculation and payment of the tax imposed by this article and any credit calculated on taxes paid pursuant to this article by an electing partnership or electing S corporation to a partner, member or shareholder of such entity that is eligible for or claims to be eligible for a credit under subsection (a) of section eight hundred sixty-three of this article.",
          "role": "complete_article_search",
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          "source_sha256": "083de34f4a4a6906b3721910a11923ea6f379f4a2ce4aa0381deb5de066e9d0e",
          "source_url": "https://www.nysenate.gov/legislation/laws/TAX/866"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "N.Y. Tax Law §860(h) and §§860-866 complete search",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(h) Pass-through entity taxable income. Pass-through entity taxable income means: (1) In the case of an electing partnership, the sum of (i) all items of income, gain, loss, or deduction derived from or connected with New York sources to the extent they are included in the taxable income of a nonresident partner subject to tax under article twenty-two, under paragraph one of subsection (a) of section six hundred thirty-two of this chapter; (ii) all items of income, gain, loss, or deduction to the extent they are included in the taxable income of a resident partner subject to tax under article twenty-two of this chapter; and (iii) all pass-through entity taxes including taxes paid under this article to New York, taxes paid under article twenty-four-B of this chapter to the city of New York, and taxes paid to other jurisdictions that are substantially similar to the taxes paid under this article, to the extent that, for federal income tax purposes, the taxes are paid and deducted in the taxable year, and are included in the taxable income of the partners subject to tax under article twenty-two of this chapter for the taxable year. (2) In the case of an electing standard S corporation, the sum of (i) all items of income, gain, loss, or deduction derived from or connected with New York sources to the extent they would be included under paragraph two of subsection (a) of section six hundred thirty-two of this chapter in the taxable income of a shareholder subject to tax under article twenty-two of this chapter; and (ii) all pass-through entity taxes including taxes paid under this article to New York, taxes paid under article twenty-four-B of this chapter to the city of New York, and taxes paid to other jurisdictions that are substantially similar to the taxes paid under this article, to the extent that, for federal income tax purposes, the taxes are paid and deducted in the taxable year, and are included in the taxable income of the shareholders subject to tax under article twenty-two of this chapter for the taxable year. (3) In the case of an electing resident S corporation, the sum of (i) all items of income, gain, loss, or deduction to the extent they are included in the taxable income of a shareholder subject to tax under article twenty-two of this chapter; and (ii) all pass-through entity taxes including taxes paid under this article to New York, taxes paid under article twenty-four-B of this chapter to the city of New York, and taxes paid to other jurisdictions that are substantially similar to taxes paid under this article, to the extent that, for federal income tax purposes, the taxes are paid and deducted in the taxable year, and are included in the taxable income of the shareholders subject to tax under article twenty-two of this chapter for the taxable year.",
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      "source_url": "https://www.nysenate.gov/legislation/laws/TAX/860",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#OH.llc.base_tax_locator.commercial_activity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The CAT rate and exclusion-amount computation are set in R.C. 5751.03; the levy itself is R.C. 5751.02.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5751.03",
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      "quote": "The rate of tax levied under section 5751.02 of the Revised Code for each tax period shall be two and six-tenths mills per dollar times the taxpayer's taxable gross receipts for the tax period after subtracting the exclusion amount for the calendar year.",
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      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.03",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#OH.llc.base_tax_locator.electing_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The electing tax's rate is set in R.C. 5747.38(B); the annual return is R.C. 5747.42(A)(2).",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.38(B)(2)",
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      "publish_status": "publish_ready",
      "quote": "the rate equal to the tax rate imposed on taxable business income under division (A)(4)(a) of section 5747.02 of the Revised Code applicable to that taxable year.",
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      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#OH.llc.base_tax_locator.pass_through_entity_withholding_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The withholding tax's rate and base are set in R.C. 5747.41 (rate) and R.C. 5733.40 (adjusted qualifying amount); the return is R.C. 5747.42.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.41, paragraph 1",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "at a rate equal to the tax rate imposed on taxable business income under division (A)(4)(a) of section 5747.02 of the Revised Code.",
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      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#OH.llc.does_not_reach.commercial_activity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "No stated limit on the gross-receipts exclusions themselves was located in R.C. 5751.01(F)(1)-(2).",
      "fetch_event_id": null,
      "pinpoint": "Full-text search of R.C. 5751.01(F)(1)-(2), the CAT gross-receipts definition and its lettered exclusions (a)-(vv)",
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      "publish_status": "publish_ready",
      "quote": null,
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      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.01",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#OH.llc.does_not_reach.electing_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Full-text search of R.C. 5747.38 and 5747.39; no holding or passive carve-out located",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419.html",
      "snapshot_resolved": true,
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      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.does_not_reach.pass_through_entity_withholding_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5733.401(C)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Notwithstanding division (C)(1) of this section, the portion of the investment pass-through entity's net income attributable to net management fees shall not be excluded from the calculation of the adjusted qualifying amount if such net management fees exceed five per cent of the entity's net income calculated in accordance with generally accepted accounting principles.",
      "readiness": "ready",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "cb389b30504516c5af2c891cf7af1865a09a62153d1f63bfd70064421107ff9f",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5733.401",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.effective_period.commercial_activity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5751.02, codes.ohio.gov current-version effective-date line",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective: June 15, 2026",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/oh-code-5751-02-cat-levy.html",
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      "source_sha256": "293b66c303dd4a965ed223019069f2459c7edb00f56c6dc5ac3abcdad039eedd",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.02",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.effective_period.electing_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.38, codes.ohio.gov current-version effective-date line",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective: September 30, 2025",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.effective_period.pass_through_entity_withholding_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.41, codes.ohio.gov current-version effective-date line",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective: June 14, 2022",
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      "snapshot_resolved": true,
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      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.41",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.filing_rule.commercial_activity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5751.01(D), (E)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "\"Taxpayer\" means any person, or any group of persons in the case of a consolidated elected taxpayer or combined taxpayer treated as one taxpayer, required to register or pay tax under this chapter. \"Taxpayer\" does not include excluded persons.\n(E) \"Excluded person\" means any of the following:\n(1) Any person with not more than one hundred fifty thousand dollars of taxable gross receipts during the calendar year.",
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      "source_sha256": "e7bc9dbfb0703fdf1ce2b06a6e740f55dbaad88288b1e5e97e28edb204abc8d1",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.01",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.filing_rule.electing_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "R.C. 5747.42(A)(2)",
          "quote": "every qualifying entity or electing pass-through entity that is subject to the tax imposed by section 5733.41 , 5747.38 , or 5747.41 of the Revised Code shall file an annual return as follows: [...] (2) For an electing pass-through entity, on or before the fifteenth day of April following the end of the entity's taxable year that ends in the preceding calendar year.",
          "role": "statutory_filing_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/b34aae51cfeb3abb55c7881d0a79af9f560011f8cadf2ce31027cfa1639cd9d4.html",
          "source_sha256": "b34aae51cfeb3abb55c7881d0a79af9f560011f8cadf2ce31027cfa1639cd9d4",
          "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.42"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.38(C)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A pass-through entity that is not a disregarded entity, as defined in section 5733.01 of the Revised Code, may elect to be subject to the tax levied under this section by filing with the tax commissioner a form prescribed by the commissioner making such election on or before the deadline to file the return under section 5747.42 of the Revised Code for the taxable year. Such election applies only to the taxable year for which the election is made and is, once made, irrevocable for that year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.filing_rule.pass_through_entity_withholding_tax": {
      "additional_sources": [
        {
          "pinpoint": "R.C. 5747.42(A)(1)",
          "quote": "every qualifying entity or electing pass-through entity that is subject to the tax imposed by section 5733.41 , 5747.38 , or 5747.41 of the Revised Code shall file an annual return as follows: (1) For a qualifying entity, on or before the fifteenth day of the fourth month following the end of the entity's qualifying taxable year;",
          "role": "statutory_filing_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/b34aae51cfeb3abb55c7881d0a79af9f560011f8cadf2ce31027cfa1639cd9d4.html",
          "source_sha256": "b34aae51cfeb3abb55c7881d0a79af9f560011f8cadf2ce31027cfa1639cd9d4",
          "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.42"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.41, paragraph 2; R.C. 5747.42(A)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax imposed by this section applies only if the qualifying entity has nexus with this state under the Constitution of the United States for any portion of the qualifying entity's qualifying taxable year, and the sum of the qualifying entity's adjusted qualifying amounts exceeds one thousand dollars for the qualifying entity's qualifying taxable year. [...] every qualifying entity or electing pass-through entity that is subject to the tax imposed by section 5733.41 , 5747.38 , or 5747.41 of the Revised Code shall file an annual return as follows: (1) For a qualifying entity, on or before the fifteenth day of the fourth month following the end of the entity's qualifying taxable year;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/8e79cad1a66e60f6bb92acec48459dcefbe24388ff7ad2da5ed0a64ce2fe1331.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8e79cad1a66e60f6bb92acec48459dcefbe24388ff7ad2da5ed0a64ce2fe1331",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.41",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.tax_regime.commercial_activity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Ohio levies a commercial activity tax on each person with taxable gross receipts for the privilege of doing business in Ohio.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5751.02(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For the purpose of funding the needs of this state and its local governments, there is hereby levied a commercial activity tax on each person with taxable gross receipts for the privilege of doing business in this state. For the purposes of this chapter, \"doing business\" means engaging in any activity, whether legal or illegal, that is conducted for, or results in, gain, profit, or income, at any time during a calendar year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/oh-code-5751-02-cat-levy.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "293b66c303dd4a965ed223019069f2459c7edb00f56c6dc5ac3abcdad039eedd",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.02",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.tax_regime.electing_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.38(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For the same purposes for which the tax is levied under section 5747.02 of the Revised Code, a tax is hereby levied on each electing pass-through entity on the entity's qualifying taxable income for the taxable year, at the following rates: (1) For an electing pass-through entity's taxable year that begins in 2022, five per cent; (2) For an electing pass-through entity's taxable year that begins in 2023 and in any year thereafter, the rate equal to the tax rate imposed on taxable business income under division (A)(4)(a) of section 5747.02 of the Revised Code applicable to that taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.tax_regime.pass_through_entity_withholding_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.41, paragraphs 1-2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For the same purposes for which the tax is levied under section 5747.02 of the Revised Code, there is hereby levied a withholding tax on every qualifying pass-through entity having at least one qualifying investor who is an individual and on every qualifying trust having at least one qualifying beneficiary who is an individual. The withholding tax imposed by this section is imposed on the sum of the adjusted qualifying amounts of a qualifying pass-through entity's qualifying investors who are individuals and on the sum of the adjusted qualifying amounts of a qualifying trust's qualifying beneficiaries, at a rate equal to the tax rate imposed on taxable business income under division (A)(4)(a) of section 5747.02 of the Revised Code. The tax imposed by this section applies only if the qualifying entity has nexus with this state under the Constitution of the United States for any portion of the qualifying entity's qualifying taxable year, and the sum of the qualifying entity's adjusted qualifying amounts exceeds one thousand dollars for the qualifying entity's qualifying taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/8e79cad1a66e60f6bb92acec48459dcefbe24388ff7ad2da5ed0a64ce2fe1331.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8e79cad1a66e60f6bb92acec48459dcefbe24388ff7ad2da5ed0a64ce2fe1331",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.41",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.treatment.commercial_activity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5751.01(F)(1)(c), (F)(2)(a)-(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "\"Gross receipts\" means the total amount realized by a person, without deduction for the cost of goods sold or other expenses incurred, that contributes to the production of gross income of the person, including the fair market value of any property and any services received, and any debt transferred or forgiven as consideration. [...] (1) The following are examples of gross receipts: [...] (c) Amounts realized from another's use or possession of the taxpayer's property or capital; [...] (2) \"Gross receipts\" excludes the following amounts: (a) Interest income except interest on credit sales; (b) Dividends and distributions from corporations, and distributive or proportionate shares of receipts and income from a pass-through entity as defined under section 5733.04 of the Revised Code",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/oh-code-5751-01-cat-definitions.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "e7bc9dbfb0703fdf1ce2b06a6e740f55dbaad88288b1e5e97e28edb204abc8d1",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.01",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.treatment.electing_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5747.38(A)(4)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The portion of an electing pass-through entity's income that is business income, subject to the applicable adjustments in divisions (A)(2) to (7) of section 5733.40 of the Revised Code, multiplied by the fraction described in division (B)(1) of that section;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f38ff72acaf99a60f1338b16a3f32f8f36bcb0fd420c1fce8a67e71936f1419",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OH.llc.treatment.pass_through_entity_withholding_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.C. 5733.401(C)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Except as otherwise provided in division (C)(2) of this section, for the purposes of division (A) of section 5733.40 of the Revised Code, an investment pass-through entity shall exclude from the calculation of the adjusted qualifying amount  the portion of the investment pass-though entity's net income attributable to transaction fees in connection with the acquisition, ownership, or disposition of intangible property; loan fees; financing fees; consent fees; waiver fees; application fees; net management fees; dividend income; interest income; net capital gains from the sale, exchange, or other disposition of intangible property; and all types and classifications of income attributable to distributive shares of income from other pass-through entities.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OH/snapshots/c50/OH/cb389b30504516c5af2c891cf7af1865a09a62153d1f63bfd70064421107ff9f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "cb389b30504516c5af2c891cf7af1865a09a62153d1f63bfd70064421107ff9f",
      "source_url": "https://codes.ohio.gov/ohio-revised-code/section-5733.401",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The corporate taxable-income definitions, imposition, and Oklahoma adjustments are located at Title 68 §§ 2353, 2355(H), and 2358.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355(H)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "H. Corporations. For all taxable years beginning after December 31, 2021, a tax is hereby imposed upon the Oklahoma taxable income of every corporation doing business within this state or deriving income from sources within this state in an amount equal to four percent (4%) thereof.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "base_tax_locator",
      "display": "The entity-income definition, member classes, tax calculation, and election rules are located at Title 68 §§ 2355.1P-2 and 2355.1P-4.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355.1P-4(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. For tax years beginning on or after January 1, 2022, there is hereby levied on each electing pass-through entity the pass- through entity tax which shall be calculated as follows: 1. With regard to each member of an electing pass-through entity, the electing pass-through entity shall multiply such member's Oklahoma distributive share of the electing pass-through entity's Oklahoma net entity income for the tax year by: a. the highest Oklahoma marginal income tax rate levied on the taxable income of natural persons pursuant to Section 2355 of this title if the member is an individual, trust, or estate, b. four percent (4%) if the member is classified as a corporation pursuant to the Internal Revenue Code, and is not classified as an S corporation, Oklahoma Statutes - Title 68. Revenue and Taxation Page 759 c. four percent (4%) if the member is a pass-through entity, d. four percent (4%) if the member is a financial institution subject to tax imposed pursuant to the provisions of Section 2370 of this title, and e. the highest Oklahoma marginal income tax rate that would be applicable to any item of the electing pass- through entity's income or gain without the election made pursuant to subsection F of this section, if the member is an organization described in Section 2359 of this title; and 2. The electing pass-through entity shall aggregate the amounts determined with respect to all members pursuant to paragraph 1 of this subsection and the pass-through entity tax for the applicable tax year shall be equal to such aggregated tax amount for the tax year with respect to which the election has been made.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355(H)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There shall be no additional Oklahoma income tax imposed on accumulated taxable income or on undistributed personal holding company income as those terms are defined in the Internal Revenue Code of 1986, as amended.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355.1P-2(5)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "5. \"Oklahoma net entity income\" or \"Oklahoma net entity loss\" means the positive or negative sum of an electing pass-through Oklahoma Statutes - Title 68. Revenue and Taxation Page 758 entity's items of Oklahoma income, gain, loss, and deduction determined under Section 2351 et seq. of Title 68 of the Oklahoma Statutes, regardless of whether any such items are required for federal income tax purposes to be separately stated; and",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The current corporate rate provision applies to taxable years beginning after December 31, 2021.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355(H)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "H. Corporations. For all taxable years beginning after December 31, 2021, a tax is hereby imposed upon the Oklahoma taxable income of every corporation doing business within this state or deriving income from sources within this state in an amount equal to four percent (4%) thereof.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The current pass-through entity tax calculation applies to tax years beginning on or after January 1, 2022.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355.1P-4(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. For tax years beginning on or after January 1, 2022, there is hereby levied on each electing pass-through entity the pass- through entity tax which shall be calculated as follows: 1. With regard to each member of an electing pass-through entity, the electing pass-through entity shall multiply such member's Oklahoma distributive share of the electing pass-through entity's Oklahoma net entity income for the tax year by: a. the highest Oklahoma marginal income tax rate levied on the taxable income of natural persons pursuant to Section 2355 of this title if the member is an individual, trust, or estate, b. four percent (4%) if the member is classified as a corporation pursuant to the Internal Revenue Code, and is not classified as an S corporation, Oklahoma Statutes - Title 68. Revenue and Taxation Page 759 c. four percent (4%) if the member is a pass-through entity, d. four percent (4%) if the member is a financial institution subject to tax imposed pursuant to the provisions of Section 2370 of this title, and e. the highest Oklahoma marginal income tax rate that would be applicable to any item of the electing pass- through entity's income or gain without the election made pursuant to subsection F of this section, if the member is an organization described in Section 2359 of this title; and 2. The electing pass-through entity shall aggregate the amounts determined with respect to all members pursuant to paragraph 1 of this subsection and the pass-through entity tax for the applicable tax year shall be equal to such aggregated tax amount for the tax year with respect to which the election has been made.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Every corporation files an annual return stating taxable income and the Oklahoma adjustments, signed by the specified corporate officer.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2368(F)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "F. Every corporation shall make a return for each taxable year stating the taxable income and the adjustments provided in Section 2351 et seq. of this title to arrive at Oklahoma taxable income. In addition, corporations electing subchapter S treatment pursuant to the Internal Revenue Code and Section 2351 et seq. of this title, shall include a schedule showing the distribution to shareholders of the various items of income as per the federal return and the adjustments for Oklahoma. All corporation returns shall be signed by the president, vice president, or other principal officer and the corporate seal impressed. In cases where receivers, trustees in bankruptcy, or assignees are operating the property or business of corporations, such receivers, trustees, or assignees shall make a return for such corporations in the same manner and form as corporations are required to make returns. Any tax due on the basis of such returns made by receivers, trustees, or assignees shall be collected in the same manner as if collected from the corporations of whose business or property they have custody and control.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Okla. Stat. tit. 68, § 2355.1P-4(F)",
          "quote": "F. Any entity required to file an Oklahoma partnership income tax return or an Oklahoma S corporation income tax return may elect to become an electing pass-through entity. The election shall be made on such form and in such manner as the Oklahoma Tax Commission may prescribe, and any election under this subsection shall have priority over and revoke any election to file a composite Oklahoma partnership return or requirement of a Subchapter S corporation to report and pay tax on behalf of a nonresident shareholder for the same tax year. An election may also be made by filing an income tax Oklahoma Statutes - Title 68. Revenue and Taxation Page 760 return prior to but not later than the due date of the applicable income tax return, including any extension.",
          "role": "election_filing_rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
          "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
          "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf"
        },
        {
          "pinpoint": "Okla. Stat. tit. 68, § 2355.1P-4(H)",
          "quote": "H. The election authorized by the provisions of this section shall be made pursuant to procedures prescribed by the Tax Commission and shall be filed (i) within sixty (60) days of enactment and pursuant to procedures prescribed by the Oklahoma Tax Commission for any income tax year beginning on or after January 1, 2019, and prior to January 1, 2020, or (ii) for any income tax year beginning on or after January 1, 2020, at any time during the preceding tax year or two (2) months and fifteen (15) days after the beginning of the tax year or by filing a timely income tax return as authorized pursuant to subsection F of this section. Any such election shall be binding until revoked pursuant to procedures prescribed by the Tax Commission. The effective date of a revocation (i) made within two (2) months and fifteen (15) days of the electing pass-through entity's taxable year shall be the first day of such taxable year and (ii) made during the electing pass- through entity's taxable year but after such fifteenth day shall be effective on the first day of the following taxable year. No election made by a pass-through entity with respect to income tax to be paid by such entity using the calculations prescribed by this section shall be binding on any other pass-through entity, and each pass-through entity shall be able to make an election under the provisions of this act independently.",
          "role": "election_timing_and_revocation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
          "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
          "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355.1P-4(C)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "C. The pass-through entity tax shall be due and payable on the same date as provided for the filing of the electing pass-through entity's Oklahoma income tax return, and for tax years beginning on or after January 1, 2020, estimated tax payments shall be required as provided in Section 2385.9 of this title.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Oklahoma imposes corporate income tax on the Oklahoma taxable income of every corporation doing business in the state or deriving income from Oklahoma sources.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355(H)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "H. Corporations. For all taxable years beginning after December 31, 2021, a tax is hereby imposed upon the Oklahoma taxable income of every corporation doing business within this state or deriving income from sources within this state in an amount equal to four percent (4%) thereof.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Oklahoma levies the pass-through entity tax on each electing pass-through entity for tax years beginning on or after January 1, 2022.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355.1P-4(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. For tax years beginning on or after January 1, 2022, there is hereby levied on each electing pass-through entity the pass- through entity tax which shall be calculated as follows: 1. With regard to each member of an electing pass-through entity, the electing pass-through entity shall multiply such member's Oklahoma distributive share of the electing pass-through entity's Oklahoma net entity income for the tax year by: a. the highest Oklahoma marginal income tax rate levied on the taxable income of natural persons pursuant to Section 2355 of this title if the member is an individual, trust, or estate, b. four percent (4%) if the member is classified as a corporation pursuant to the Internal Revenue Code, and is not classified as an S corporation, Oklahoma Statutes - Title 68. Revenue and Taxation Page 759 c. four percent (4%) if the member is a pass-through entity, d. four percent (4%) if the member is a financial institution subject to tax imposed pursuant to the provisions of Section 2370 of this title, and e. the highest Oklahoma marginal income tax rate that would be applicable to any item of the electing pass- through entity's income or gain without the election made pursuant to subsection F of this section, if the member is an organization described in Section 2359 of this title; and 2. The electing pass-through entity shall aggregate the amounts determined with respect to all members pursuant to paragraph 1 of this subsection and the pass-through entity tax for the applicable tax year shall be equal to such aggregated tax amount for the tax year with respect to which the election has been made.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.treatment.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Okla. Stat. tit. 68, § 2355(H)",
          "quote": "There shall be no additional Oklahoma income tax imposed on accumulated taxable income or on undistributed personal holding company income as those terms are defined in the Internal Revenue Code of 1986, as amended.",
          "role": "no_additional_personal_holding_company_tax",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
          "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
          "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Section 2355(H) taxes every corporation meeting its business-or-income scope; the complete-act search located no general holding-company exemption.",
      "fetch_event_id": null,
      "pinpoint": "Okla. Stat. tit. 68, § 2355(H)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "H. Corporations. For all taxable years beginning after December 31, 2021, a tax is hereby imposed upon the Oklahoma taxable income of every corporation doing business within this state or deriving income from sources within this state in an amount equal to four percent (4%) thereof.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OK.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "The elective tax applies to Oklahoma net entity income without a separately stated holding- or passive-entity treatment.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OK/snapshots/c50/000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "000e4e3b7b834aad968b862d35e24cf4b443af0877e17993163afb2b179ff901",
      "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OR.llc.base_tax_locator.corporate_activity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The CAT imposition, rate locator and commercial-activity base are in ORS 317A.116, 317A.125 and 317A.100(1).",
      "fetch_event_id": null,
      "pinpoint": "ORS 317A.116(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A corporate activity tax is imposed on each person with taxable commercial activity for the privilege of doing business in this state. The tax is imposed upon persons with substantial nexus with this state. The tax imposed under this section is not a transactional tax and is not subject to the Interstate Income Act of 1959 (P.L. 86-272). The tax imposed under this section is in addition to any other taxes or fees imposed under the tax laws of this state. The tax imposed under this section is imposed on the person with the commercial activity and is not a tax imposed directly on a purchaser. The tax imposed under this section is an annual privilege tax for the tax year and shall be remitted quarterly to the Department of Revenue. A taxpayer is subject to the annual corporate activity tax for doing business during any portion of such tax year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/or-ors-317a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b8f3351257144ae5b4312ff0be6227e9a315ff309114ca1a1274e928c5de8faf",
      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317A.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OR.llc.base_tax_locator.corporation_excise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The excise-tax rate, imposition, minimum tax and dividend modification are located in ORS 317.061, 317.070, 317.090 and 317.267.",
      "fetch_event_id": null,
      "pinpoint": "ORS 317.070",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Every centrally assessed corporation, the property of which is assessed by the Department of Revenue under ORS 308.505 to 308.674, and every mercantile, manufacturing and business corporation and every financial institution doing business within this state, except as provided in ORS 317.080 and 317.090, shall annually pay to this state, for the privilege of carrying on or doing business by it within this state, an excise tax according to or measured by its Oregon taxable income, to be computed in the manner provided by this chapter, at the rate provided in ORS 317.061.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/or-ors-317.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e9c1529fe32aedb68b002d03a466fd9894d54dbe679a909e150cf21298bb5c4",
      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OR.llc.base_tax_locator.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "ORS 318.031",
          "role": "chapter_317_incorporation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/or-ors-318.html",
          "source_sha256": "1adbc86bf8c5ef1fe41bd65e9aec00050918b504d19d746643de9a57ce9063d6",
          "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors318.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The income-tax imposition and incorporation rule are in ORS 318.020 and 318.031; chapter 317 contains the rate and dividend modification.",
      "fetch_event_id": null,
      "pinpoint": "ORS 318.020(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There hereby is imposed upon every corporation for each taxable year a tax at the rate provided in ORS 317.061 upon its Oregon taxable income derived from sources within this state, other than income for which the corporation is subject to the tax imposed by ORS chapter 317 according to or measured by its Oregon taxable income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/or-ors-318.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "1adbc86bf8c5ef1fe41bd65e9aec00050918b504d19d746643de9a57ce9063d6",
      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors318.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OR.llc.base_tax_locator.pass_through_business_alternative_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Oregon Laws 2026, chapter 75, section 9",
          "role": "current_amendment",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/c50/orlaw2026-75/OR/0e323352cafe8a27bb75194f2185ff7b58dcb1603ff6986e9acebfb18a20f419.pdf",
          "source_sha256": "0e323352cafe8a27bb75194f2185ff7b58dcb1603ff6986e9acebfb18a20f419",
          "source_url": "https://www.oregonlegislature.gov/bills_laws/lawsstatutes/2026orLaw0075.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective regime's distributive-proceeds definition, tax base and rate are in sections 2(1) and 3(5)-(6), chapter 589, Oregon Laws 2021, as amended.",
      "fetch_event_id": null,
      "pinpoint": "Oregon Laws 2021, chapter 589, section 3(5)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The tax imposed on a pass-through entity pursuant to this section shall be determined with respect to the sum of each member’s share of distributive proceeds attributable to the pass-through entity for the tax year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/OR/3f8190cb35dd12f797542ac06a3162b6afcf2c5a76dce37b4740c982606e119c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3f8190cb35dd12f797542ac06a3162b6afcf2c5a76dce37b4740c982606e119c",
      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OR.llc.does_not_reach.corporate_activity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The quoted interest, asset-disposition, dividend and pass-through-distribution receipts do not enter commercial activity, subject to the two stated interest exceptions.",
      "fetch_event_id": null,
      "pinpoint": "ORS 317A.100(1)(b)(A)-(B), (BB)-(CC)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "“Commercial activity” does not include: (A) Interest income except: (i) Interest on credit sales; or (ii) Interest income, including service charges, received by financial institutions; (B) Receipts from the sale, exchange or other disposition of an asset described in section 1221 or 1231 of the Internal Revenue Code, without regard to the length of time the person held the asset; […] (BB) Dividends received; (CC) Distributive income received from a pass-through entity;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/or-ors-317a.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b8f3351257144ae5b4312ff0be6227e9a315ff309114ca1a1274e928c5de8faf",
      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317A.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OR.llc.does_not_reach.corporation_excise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "ORS 317.267(2)(c)-(f)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A dividend that is not treated as a dividend under section 243(d) of the Internal Revenue Code may not be treated as a dividend for purposes of this subsection. (d) If a dividends received deduction is not allowed for federal tax purposes because of section 246(a) or (c) of the Internal Revenue Code, a subtraction may not be made under this subsection for received dividends that are described in section 246(a) or (c) of the Internal Revenue Code. (e) In the case of any dividend received from an alien, domestic or foreign insurer, as defined in ORS 731.082, that would be included in the taxpayer’s consolidated Oregon return but for the application of ORS 317.710 (5) or (7), this subsection shall be applied by substituting “100 percent” for “70 percent.” (f) A subtraction under this subsection is not allowed for any amount of foreign-source dividend income, as described in section 245A of the Internal Revenue Code, that is included in gross income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/or-ors-317.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e9c1529fe32aedb68b002d03a466fd9894d54dbe679a909e150cf21298bb5c4",
      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#OR.llc.does_not_reach.corporation_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "ORS 318.031",
          "role": "chapter_317_incorporation",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/or-ors-318.html",
          "source_sha256": "1adbc86bf8c5ef1fe41bd65e9aec00050918b504d19d746643de9a57ce9063d6",
          "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors318.html"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "ORS 317.267(2)(c)-(f)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A dividend that is not treated as a dividend under section 243(d) of the Internal Revenue Code may not be treated as a dividend for purposes of this subsection. (d) If a dividends received deduction is not allowed for federal tax purposes because of section 246(a) or (c) of the Internal Revenue Code, a subtraction may not be made under this subsection for received dividends that are described in section 246(a) or (c) of the Internal Revenue Code. (e) In the case of any dividend received from an alien, domestic or foreign insurer, as defined in ORS 731.082, that would be included in the taxpayer’s consolidated Oregon return but for the application of ORS 317.710 (5) or (7), this subsection shall be applied by substituting “100 percent” for “70 percent.” (f) A subtraction under this subsection is not allowed for any amount of foreign-source dividend income, as described in section 245A of the Internal Revenue Code, that is included in gross income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/OR/snapshots/or-ors-317.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "3e9c1529fe32aedb68b002d03a466fd9894d54dbe679a909e150cf21298bb5c4",
      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
      "table": "holding_tax"
    },
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      "display": "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.",
      "fetch_event_id": null,
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      "quote": "For purposes of the corporate activity tax imposed under ORS 317A.116, every person doing business in this state with commercial activity for the tax year in excess of $1 million shall file an annual return not later than the 15th day of the fourth month following the end of the tax year. If the 15th day of the fourth month falls on a Saturday, Sunday or legal holiday, including any legal holiday in the District of Columbia, the return is due on the next business day following the Saturday, Sunday or legal holiday. The return must be filed with the Department of Revenue in a form prescribed by the department.",
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      "display": "A chapter 317 or 318 return is due on the 15th day of the month following the corresponding federal-return due date.",
      "fetch_event_id": null,
      "pinpoint": "ORS 314.385(1)(b)",
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      "publish_status": "publish_ready",
      "quote": "For purposes of ORS chapters 317 and 318, returns shall be filed with the department on or before the 15th day of the month following the due date of the corresponding federal return for the tax year, as prescribed under the Internal Revenue Code and the regulations adopted pursuant thereto.",
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      "quote": "For purposes of ORS chapters 317 and 318, returns shall be filed with the department on or before the 15th day of the month following the due date of the corresponding federal return for the tax year, as prescribed under the Internal Revenue Code and the regulations adopted pursuant thereto.",
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      "display": "An electing pass-through entity must file an entity tax return with payment by the chapter 316 return date provided in ORS 314.385.",
      "fetch_event_id": null,
      "pinpoint": "Oregon Laws 2021, chapter 589, section 3(8)",
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      "publish_status": "publish_ready",
      "quote": "Pass-through entities that have made an election under this section shall file an entity tax return. The return shall be accompanied by payment and shall be due on the date applicable to returns due under ORS chapter 316, as provided in ORS 314.385.",
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      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
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      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Oregon imposes an annual Corporate Activity Tax on each person with taxable commercial activity and substantial Oregon nexus.",
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      "quote": "A corporate activity tax is imposed on each person with taxable commercial activity for the privilege of doing business in this state. The tax is imposed upon persons with substantial nexus with this state. The tax imposed under this section is not a transactional tax and is not subject to the Interstate Income Act of 1959 (P.L. 86-272). The tax imposed under this section is in addition to any other taxes or fees imposed under the tax laws of this state. The tax imposed under this section is imposed on the person with the commercial activity and is not a tax imposed directly on a purchaser. The tax imposed under this section is an annual privilege tax for the tax year and shall be remitted quarterly to the Department of Revenue. A taxpayer is subject to the annual corporate activity tax for doing business during any portion of such tax year.",
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      "display": "Oregon imposes the Corporation Income Tax under ORS 318.020(1) on the corporations and Oregon income stated in that provision.",
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      "quote": "There hereby is imposed upon every corporation for each taxable year a tax at the rate provided in ORS 317.061 upon its Oregon taxable income derived from sources within this state, other than income for which the corporation is subject to the tax imposed by ORS chapter 317 according to or measured by its Oregon taxable income.",
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      "quote": "A pass-through entity may elect to be liable for and pay a pass-through business alternative income tax if all members of the pass-through entity are: (a) Individuals subject to the personal income tax imposed under ORS chapter 316; or (b) Entities that are pass-through entities owned entirely by individuals subject to the personal income tax imposed under ORS chapter 316.",
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      "quote": "“Commercial activity” does not include: (A) Interest income except: (i) Interest on credit sales; or (ii) Interest income, including service charges, received by financial institutions; (B) Receipts from the sale, exchange or other disposition of an asset described in section 1221 or 1231 of the Internal Revenue Code, without regard to the length of time the person held the asset; […] (BB) Dividends received; (CC) Distributive income received from a pass-through entity;",
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      "quote": "To derive Oregon taxable income, after the modification prescribed under subsection (1) of this section, there shall be subtracted from federal taxable income an amount equal to 70 percent of dividends (determined without regard to section 78 of the Internal Revenue Code) received or deemed received from corporations if such dividends are included in federal taxable income.",
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      "quote": "To derive Oregon taxable income, after the modification prescribed under subsection (1) of this section, there shall be subtracted from federal taxable income an amount equal to 70 percent of dividends (determined without regard to section 78 of the Internal Revenue Code) received or deemed received from corporations if such dividends are included in federal taxable income.",
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      "capture_date": "2026-10-03",
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      "display": "No holding carve-out was located; the elective tax base expressly uses distributive proceeds that include dividends, royalties, interest, rents and gains.",
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      "pinpoint": "Oregon Laws 2021, chapter 589, sections 2(1) and 3(5)",
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      "quote": "“Distributive proceeds” means the net income, dividends, royalties, interest, rents, guaranteed payments and gains of a pass-through entity, derived from or connected with sources within this state. […] The tax imposed on a pass-through entity pursuant to this section shall be determined with respect to the sum of each member’s share of distributive proceeds attributable to the pass-through entity for the tax year.",
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      "source_sha256": "3f8190cb35dd12f797542ac06a3162b6afcf2c5a76dce37b4740c982606e119c",
      "source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#PA.llc.base_tax_locator.corporate_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Article IV §§401(3) and 402(b) locate the taxable-income base and dated rate schedule.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §402(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The annual rate of tax on corporate net income imposed by subsection (a) for taxable years beginning for the calendar year or fiscal year on or after the dates set forth shall be as follows:",
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      "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#PA.llc.base_tax_locator.s_corporation_built_in_gains_tax": {
      "additional_sources": [
        {
          "pinpoint": "Tax Reform Code art. IV, §402(b)",
          "quote": "The annual rate of tax on corporate net income imposed by subsection (a) for taxable years beginning for the calendar year or fiscal year on or after the dates set forth shall be as follows:",
          "role": "corporate net income tax rate schedule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/PA/snapshots/c50/fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4.html",
          "source_sha256": "fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4",
          "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Article IV §§401(3)1(p) and 402(b) locate the built-in-gain tax base and corporate net income tax rate schedule.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §401(3)1(p)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning on or after January 1, 1998, in the case of a corporation that is a Pennsylvania S corporation, as defined in section 301(n.1), the term \"taxable income\" shall mean such corporation's net recognized built-in gain to the extent of and as determined for Federal income tax purposes under section 1374(d)(2) of the Internal Revenue Code of 1986 (Public Law 99-514, 26 U.S.C. § 1374). For purposes of this article, a Pennsylvania S corporation and each qualified Subchapter S subsidiary, as defined in section 301(o.3), shall be treated as separate corporations.",
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      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#PA.llc.does_not_reach.corporate_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "For tax years beginning after 1990, the stated dividend modification is limited to §78 amounts and qualifying foreign-corporation dividends.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §401(3)1(b)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Additional deductions shall be allowed from taxable income on account of any dividends received from any other corporation but only to the extent that such dividends are included in taxable income as returned to and ascertained by the Federal Government. For tax years beginning on or after January 1, 1991, additional deductions shall only be allowed for amounts included, under section 78 of the Internal Revenue Code of 1986 (Public Law 99-514, 26 U.S.C. § 78), in taxable income returned to and ascertained by the Federal Government and for the amount of any dividends received from a foreign corporation included in taxable income to the extent such dividends would be deductible in arriving at Federal taxable income if received from a domestic corporation.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/PA/snapshots/c50/fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#PA.llc.does_not_reach.s_corporation_built_in_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The Article IV taxable-income definition reaches only net recognized built-in gain as federally determined under §1374(d)(2).",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §401(3)1(p)",
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      "publish_status": "publish_ready",
      "quote": "For taxable years beginning on or after January 1, 1998, in the case of a corporation that is a Pennsylvania S corporation, as defined in section 301(n.1), the term \"taxable income\" shall mean such corporation's net recognized built-in gain to the extent of and as determined for Federal income tax purposes under section 1374(d)(2) of the Internal Revenue Code of 1986 (Public Law 99-514, 26 U.S.C. § 1374). For purposes of this article, a Pennsylvania S corporation and each qualified Subchapter S subsidiary, as defined in section 301(o.3), shall be treated as separate corporations.",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4",
      "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
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    "holding_tax:pp-holding-entity-tax#PA.llc.effective_period.corporate_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The Article IV rate schedule states an ongoing period beginning January 1, 2031, after its intervening dated periods.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §402(b), final schedule row",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "January 1, 2031, and each taxable year thereafter",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/PA/snapshots/c50/fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4",
      "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#PA.llc.effective_period.s_corporation_built_in_gains_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "The Pennsylvania S-corporation built-in-gain taxable-income rule applies to taxable years beginning on or after January 1, 1998.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §401(3)1(p)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "For taxable years beginning on or after January 1, 1998, in the case of a corporation that is a Pennsylvania S corporation, as defined in section 301(n.1), the term \"taxable income\" shall mean such corporation's net recognized built-in gain to the extent of and as determined for Federal income tax purposes under section 1374(d)(2) of the Internal Revenue Code of 1986 (Public Law 99-514, 26 U.S.C. § 1374). For purposes of this article, a Pennsylvania S corporation and each qualified Subchapter S subsidiary, as defined in section 301(o.3), shall be treated as separate corporations.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/PA/snapshots/c50/fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4",
      "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#PA.llc.filing_rule.corporate_net_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "Tax Reform Code art. IV, §403(a)(1)",
          "quote": "It shall be the duty of every corporation, liable to pay tax under this article, to transmit to the department, upon a form prescribed by the department, an annual report under oath or affirmation of its president, vice-president, treasurer, assistant treasurer or other authorized officers of net income taxable under the provisions of this article:",
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          "snapshot_path": "rigs/entity-research/holding-tax/discovery/PA/snapshots/c50/fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4.html",
          "source_sha256": "fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4",
          "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §403(a)(1)(iii)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "for taxable years beginning after December 31, 2020, on or before the fifteenth day of the month following the due date of the return to the Federal Government, or would be due were it to be required of such corporation, subject in all other respects to the provisions of this article.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/PA/snapshots/c50/fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4.html",
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      "source_sha256": "fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4",
      "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
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    "holding_tax:pp-holding-entity-tax#PA.llc.filing_rule.s_corporation_built_in_gains_tax": {
      "additional_sources": [
        {
          "pinpoint": "Tax Reform Code art. III, §330.1(a)",
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          "snapshot_path": "rigs/entity-research/holding-tax/discovery/PA/snapshots/c50/fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4.html",
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          "source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "A Pennsylvania S-corporation return is due thirty days after the federal corporate income-tax return due date.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. III, §330.1(b)",
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      "publish_status": "publish_ready",
      "quote": "The return shall be filed on or before thirty days after the date when the corporation's Federal income tax return is due.",
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    "holding_tax:pp-holding-entity-tax#PA.llc.tax_regime.corporate_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Article IV imposes an excise tax on a corporation exercising listed Pennsylvania privileges.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §402(a)",
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      "publish_status": "publish_ready",
      "quote": "A corporation shall be subject to and shall pay an excise tax for exercising, whether in its own name or through any person, association, business trust, corporation, joint venture, limited liability company, limited partnership, partnership or other entity, any of the following privileges:",
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      "source_sha256": "fbeb9475ab2cc4483121556709b4fe94959c78f3af2c2b044481eaee2519d9f4",
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    "holding_tax:pp-holding-entity-tax#PA.llc.tax_regime.s_corporation_built_in_gains_tax": {
      "additional_sources": [
        {
          "pinpoint": "Tax Reform Code art. IV, §402(a)",
          "quote": "A corporation shall be subject to and shall pay an excise tax for exercising, whether in its own name or through any person, association, business trust, corporation, joint venture, limited liability company, limited partnership, partnership or other entity, any of the following privileges:",
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      "capture_date": "2026-10-03",
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      "display": "For a Pennsylvania S corporation, Article IV taxable income is federally determined net recognized built-in gain.",
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      "pinpoint": "Tax Reform Code art. IV, §401(3)1(p)",
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      "quote": "For taxable years beginning on or after January 1, 1998, in the case of a corporation that is a Pennsylvania S corporation, as defined in section 301(n.1), the term \"taxable income\" shall mean such corporation's net recognized built-in gain to the extent of and as determined for Federal income tax purposes under section 1374(d)(2) of the Internal Revenue Code of 1986 (Public Law 99-514, 26 U.S.C. § 1374). For purposes of this article, a Pennsylvania S corporation and each qualified Subchapter S subsidiary, as defined in section 301(o.3), shall be treated as separate corporations.",
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    "holding_tax:pp-holding-entity-tax#PA.llc.treatment.corporate_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "Corporate taxable income receives the dividend modification stated in §401(3)1(b).",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §401(3)1(b)",
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      "quote": "Additional deductions shall be allowed from taxable income on account of any dividends received from any other corporation but only to the extent that such dividends are included in taxable income as returned to and ascertained by the Federal Government. For tax years beginning on or after January 1, 1991, additional deductions shall only be allowed for amounts included, under section 78 of the Internal Revenue Code of 1986 (Public Law 99-514, 26 U.S.C. § 78), in taxable income returned to and ascertained by the Federal Government and for the amount of any dividends received from a foreign corporation included in taxable income to the extent such dividends would be deductible in arriving at Federal taxable income if received from a domestic corporation.",
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      "capture_date": "2026-10-03",
      "claim_type": "primary statute",
      "display": "For a Pennsylvania S corporation, Article IV substitutes federally determined net recognized built-in gain as taxable income.",
      "fetch_event_id": null,
      "pinpoint": "Tax Reform Code art. IV, §401(3)1(p)",
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      "quote": "For taxable years beginning on or after January 1, 1998, in the case of a corporation that is a Pennsylvania S corporation, as defined in section 301(n.1), the term \"taxable income\" shall mean such corporation's net recognized built-in gain to the extent of and as determined for Federal income tax purposes under section 1374(d)(2) of the Internal Revenue Code of 1986 (Public Law 99-514, 26 U.S.C. § 1374). For purposes of this article, a Pennsylvania S corporation and each qualified Subchapter S subsidiary, as defined in section 301(o.3), shall be treated as separate corporations.",
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    "holding_tax:pp-holding-entity-tax#RI.llc.base_tax_locator.annual_llc_charge": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The annual-charge base is located in §7-16-67(c)(2), which cross-references the corporate minimum in §44-11-2(e); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "R.I. Gen. Laws § 7-16-67(c)(2)",
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      "quote": "(2) If the limited liability company is not treated as a corporation for purposes of federal income taxation, it shall pay a fee in an amount equal to the minimum tax imposed upon a corporation under § 44-11-2(e). The due date for a limited liability company that is not treated as a corporation for purposes of federal income taxation shall be on or before the fifteenth day of the fourth month following the close of the fiscal year.",
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    "holding_tax:pp-holding-entity-tax#RI.llc.base_tax_locator.business_corporation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "The business-corporation tax bases and minimum are located in §44-11-2(a), (c), and (e); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "R.I. Gen. Laws § 44-11-2(a), (c), (e)",
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      "quote": "(e) Minimum tax. The tax imposed upon any corporation under this section, including a small business corporation having an election in effect under subchapter S, 26 U.S.C. § 1361 et seq., shall not be less than four hundred fifty dollars ($450). For tax years beginning on or after January 1, 2017, the tax imposed shall not be less than four hundred dollars ($400).",
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      "source_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#RI.llc.treatment.business_corporation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
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      "display": "Section 44-11-2 changes the computation for a qualifying securities holder and named investment vehicles, while subsection (e) retains a minimum tax.",
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      "pinpoint": "R.I. Gen. Laws § 44-11-2(b)-(e)",
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      "quote": "(b) A corporation shall pay the amount of any tax as computed in accordance with subsection (a) after deducting from “net income,” as used in this section, fifty percent (50%) of the excess of capital gains over capital losses realized during the taxable year, if for the taxable year: (1) The corporation is engaged in buying, selling, dealing in, or holding securities on its own behalf and not as a broker, underwriter, or distributor; (2) Its gross receipts derived from these activities during the taxable year amounted to at least ninety percent (90%) of its total gross receipts derived from all of its activities during the year. “Gross receipts” means all receipts, whether in the form of money, credits, or other valuable consideration, received during the taxable year in connection with the conduct of the taxpayer’s activities. (c) A corporation shall not pay the amount of the tax computed on the basis of its net income under subsection (a), but shall annually pay to the state a tax equal to ten cents ($.10) for each one hundred dollars ($100) of gross income for the taxable year or a tax of one hundred dollars ($100), whichever tax shall be the greater, if for the taxable year the corporation is either a “personal holding company” registered under the federal Investment Company Act of 1940, 15 U.S.C. § 80a-1 et seq., “regulated investment company,” or a “real estate investment trust” as defined in the federal income tax law applicable to the taxable year. “Gross income” means gross income as defined in the federal income tax law applicable to the taxable year, plus: (1) Any interest not included in the federal gross income; minus (2) Interest on obligations of the United States or its possessions, and other interest exempt from taxation by this state; and minus (3) Fifty percent (50%) of the excess of capital gains over capital losses realized during the taxable year. (d)(1) A small business corporation having an election in effect under subchapter S, 26 U.S.C. § 1361 et seq., shall not be subject to the Rhode Island income tax on corporations, except that the corporation shall be subject to the provisions of subsection (a), to the extent of the income that is subjected to federal tax under subchapter S. Effective for tax years beginning on or after January 1, 2015, a small business corporation having an election in effect under subchapter S, 26 U.S.C. § 1361 et seq., shall be subject to the minimum tax under § 44-11-2(e). (2) The shareholders of the corporation who are residents of Rhode Island shall include in their income their proportionate share of the corporation’s federal taxable income. (3) [Deleted by P.L. 2004, ch. 595, art. 29, § 1.] (4) [Deleted by P.L. 2004, ch. 595, art. 29, § 1.] (e) Minimum tax. The tax imposed upon any corporation under this section, including a small business corporation having an election in effect under subchapter S, 26 U.S.C. § 1361 et seq., shall not be less than four hundred fifty dollars ($450). For tax years beginning on or after January 1, 2017, the tax imposed shall not be less than four hundred dollars ($400).",
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      "source_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#RI.llc.treatment.elective_pte_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary statute",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "R.I. Gen. Laws § 44-11-2.3(a)(2), (b)(1), current version",
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      "publish_status": "publish_ready",
      "quote": "“Net income” means the net ordinary income, net rental real estate income, other net rental income, guaranteed payments, and other business income less specially allocated depreciation and deductions allowed pursuant to § 179 of the United States Revenue Code (26 U.S.C. § 179), all of which would be reported on federal tax form schedules C and E. Net income for purposes of this section does not include specially allocated investment income or any other types of deductions. […] (1) For tax years beginning on or after January 1, 2019, a pass-through entity may elect to pay the state tax at the entity level at the rate of five and ninety-nine hundredths percent (5.99%).",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/RI/snapshots/ri-stat-title44-11-2-3.html",
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      "source_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.3_44-11-2.3.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#SC.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "base_tax_locator",
      "display": "The corporate income-tax base and rate are located at S.C. Code § 12-6-530.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-530",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An income tax is imposed annually at the rate of five percent on the South Carolina taxable income of every corporation, other than those described in Sections 12-6-540 and 12-6-550, and any other entity taxed using the rates of a corporation for federal income tax purposes, transacting, conducting, or doing business within this State or having income within this State, regardless of whether these activities are carried on in intrastate, interstate, or foreign commerce. The terms \"transacting\", \"conducting\", and \"doing business\" include transacting or engaging in any activity for the purpose of financial profit or gain.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
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      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#SC.llc.base_tax_locator.corporate_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "base_tax_locator",
      "display": "The corporate license-fee base, rate, and minimum are located at S.C. Code § 12-20-50(A).",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-20-50(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(A) Except as provided in Section 12-20-100, every corporation required to file an annual report shall pay an annual license fee of fifteen dollars plus one dollar for each thousand dollars, or fraction of a thousand dollars, of capital stock and paid-in or capital surplus of the corporation as shown by the records of the corporation on the first day of the taxable year in which the report is filed. In no case may the license fee provided by this section be less than twenty-five dollars. The license fee must be paid on or before the original due date for filing the annual report.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch20.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bbb5dfe08c28ea259c3f880bb82b02f461b5b0fb50e7603b2fcc48a17a4601c4",
      "source_url": "https://www.scstatehouse.gov/code/t12c020.php",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#SC.llc.base_tax_locator.qualified_entity_election": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "base_tax_locator",
      "display": "The rate schedule for the qualified-entity election is located at S.C. Code § 12-6-545(B)(2).",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-545(B)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) The rate of the income tax imposed pursuant to this subsection is:",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#SC.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "An S corporation is outside Chapter 6 tax to the extent it is exempt from federal corporate income tax; shareholder inclusion remains stated separately.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-590(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(A) Except as provided in Section 12-6-1210(F), an \"S\" Corporation having a valid federal election under the Internal Revenue Code Subchapter \"S\" is not subject to tax under this chapter to the extent it would be exempt from federal corporate income tax. Each shareholder shall include its share of South Carolina \"S\" Corporation income on the shareholder's income tax return. All of the provisions of the Internal Revenue Code apply to determine the gross income, adjusted gross income, and taxable income of an \"S\" Corporation and its shareholders subject to the modifications provided in Article 9 of this chapter and subject to allocation and apportionment as provided in Article 17 of this chapter.",
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      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#SC.llc.does_not_reach.corporate_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "The holding-company reduction is limited to the attributed parent contribution, qualifying subsidiary expansion, zone, and completion conditions stated in § 12-20-50(C).",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-20-50(C), limiting language",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(C) In addition to the provisions of subsection (B) of this section, a holding company may reduce its paid-in capital surplus by the portion of contributions to capital received from its parent corporation that is directly or indirectly used to finance a subsidiary's expansion costing in excess of one hundred million dollars, which on the date construction started is located in an Economic Impact Zone as defined in Section 12-14-30. A reduction is only allowed pursuant to this subsection for the paid-in capital surplus of the holding company attributable to this contribution to capital for expansion. Additionally, no reduction is allowed unless the expansion is completed within three years of the first contribution to capital received by the holding company, but this three-year limitation may be extended by the Department of Revenue upon written application and good cause shown. Amounts previously excluded in paid-in capital surplus pursuant to this subsection must be included in the first license tax year beginning after the period allowed for the expansion if the expansion is not timely completed.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch20.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bbb5dfe08c28ea259c3f880bb82b02f461b5b0fb50e7603b2fcc48a17a4601c4",
      "source_url": "https://www.scstatehouse.gov/code/t12c020.php",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SC.llc.does_not_reach.qualified_entity_election": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "The active-trade-or-business definition excludes passive investment income, related expense, capital gains and losses, service payments, and stated personal-service amounts.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-545(A)(1)(a)-(d)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) \"Active trade or business income or loss\" means income or loss of an individual, estate, trust, or any other entity except those taxed or exempted from tax pursuant to Sections 12-6-530 through 12-6-550 resulting from the ownership of an interest in a pass-through business. Active trade or business income or loss does not include:\n\n(a)(i) passive investment income as defined in Internal Revenue Code Section 1362(d) generated by a pass-through business and income of the same type regardless of the type of pass-through business generating it; and\n\n(ii) expenses related to passive investment;\n\n(b) capital gains and losses;\n\n(c) payments for services referred to in Internal Revenue Code Section 707(c);\n\n(d) amounts reasonably related to personal services. All amounts paid as compensation and all guaranteed payments for services, but not for the use of capital, as defined in Internal Revenue Code Section 707(c) are deemed to be reasonably related to personal services. In addition, if an owner of a pass-through entity who performs personal services for the entity is not paid a reasonable amount for those personal services as compensation or payments referred to in Internal Revenue Code Section 707(c), all of the owner's income from the entity is presumed to be amounts reasonably related to personal services. For purposes of this section, amounts reasonably related to personal services include amounts reasonably related to the personal services of the owner, the owner's spouse, and any person claimed as a dependent on the owner's income tax return.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
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      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SC.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "negative_full_text_search",
      "display": "No effective or sunset period for § 12-6-530 is stated in its history or the complete Chapter 6 search.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SC.llc.effective_period.corporate_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "The § 12-20-50(C) holding-company reduction applies to the stated increases in capital on January 1, 2003, and thereafter.",
      "fetch_event_id": null,
      "pinpoint": "Editor’s note following S.C. Code § 12-20-50",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "\"Notwithstanding the general effective date of this act, this section takes effect upon approval of this act by the Governor and applies to increases in capital over the prior year's capital on January 1, 2003, and thereafter.\"",
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      "reason_code": null,
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch20.html",
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      "source_url": "https://www.scstatehouse.gov/code/t12c020.php",
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    "holding_tax:pp-holding-entity-tax#SC.llc.effective_period.qualified_entity_election": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "The qualified-entity election first applies to tax years beginning after 2020.",
      "fetch_event_id": null,
      "pinpoint": "2021 Act No. 61, § 2, editor’s note following S.C. Code § 12-6-545",
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      "publish_status": "publish_ready",
      "quote": "\"SECTION 2. This act takes effect upon approval by the Governor and first applies to tax years beginning after 2020.\"",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
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      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
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    "holding_tax:pp-holding-entity-tax#SC.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "A corporation subject to Chapter 6 files a return; the statute separately states when an S corporation must file.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-4910(2)-(3)",
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      "publish_status": "publish_ready",
      "quote": "(2) a corporation subject to taxation under this chapter.\n\n(3) an \"S\" Corporation conducting business in South Carolina, having South Carolina gross income, or subject to the license fee requirements of Chapter 20 of this title, or having an interest in any partnership conducting business in this State.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
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      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#SC.llc.filing_rule.corporate_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "Covered corporations file an annual report with the Department of Revenue by the stated fourth-month deadline.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-20-20(A)-(B)",
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      "publish_status": "publish_ready",
      "quote": "(A) Except for those corporations described in Section 12-20-110, every domestic corporation, every foreign corporation qualified to do business in this State, and any other corporation required by Section 12-6-4910 to file income tax returns shall file an annual report with the department.\n\n(B) Unless otherwise provided, corporations shall file an annual report on or before the fifteenth day of the fourth month following the close of the taxable year.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch20.html",
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      "source_class": "S1",
      "source_sha256": "bbb5dfe08c28ea259c3f880bb82b02f461b5b0fb50e7603b2fcc48a17a4601c4",
      "source_url": "https://www.scstatehouse.gov/code/t12c020.php",
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    "holding_tax:pp-holding-entity-tax#SC.llc.filing_rule.qualified_entity_election": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "The annual election is due with the applicable return; owner exclusion depends on the qualified entity properly filing and paying the elected tax.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-545(G)(2)-(3)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) A qualified entity may elect annually under this subsection to have its income taxed on its active trade or business income at the rate provided in subsection (B)(2) imposed on the qualified entity itself. Such elections must be made no later than the due date for filing the applicable income tax return, including any extensions.\n\n(3) In computing South Carolina taxable income, a qualified owner shall exclude active trade or business income from an electing qualified entity provided that the qualified entity properly filed an income tax return and paid the taxes pursuant to this subsection that included the active trade or business income or loss.",
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      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#SC.llc.tax_regime.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-530",
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      "publish_status": "publish_ready",
      "quote": "An income tax is imposed annually at the rate of five percent on the South Carolina taxable income of every corporation, other than those described in Sections 12-6-540 and 12-6-550, and any other entity taxed using the rates of a corporation for federal income tax purposes, transacting, conducting, or doing business within this State or having income within this State, regardless of whether these activities are carried on in intrastate, interstate, or foreign commerce. The terms \"transacting\", \"conducting\", and \"doing business\" include transacting or engaging in any activity for the purpose of financial profit or gain.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
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    "holding_tax:pp-holding-entity-tax#SC.llc.tax_regime.corporate_license_fee": {
      "additional_sources": [
        {
          "pinpoint": "S.C. Code § 12-20-160",
          "quote": "For purposes of this chapter and for purposes of administrative and enforcement provisions of this title, the corporate license fee is deemed to be a tax.",
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          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch20.html",
          "source_sha256": "bbb5dfe08c28ea259c3f880bb82b02f461b5b0fb50e7603b2fcc48a17a4601c4",
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "Every corporation required to file the annual report pays the corporate license fee, which Chapter 20 deems a tax.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-20-50(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(A) Except as provided in Section 12-20-100, every corporation required to file an annual report shall pay an annual license fee of fifteen dollars plus one dollar for each thousand dollars, or fraction of a thousand dollars, of capital stock and paid-in or capital surplus of the corporation as shown by the records of the corporation on the first day of the taxable year in which the report is filed. In no case may the license fee provided by this section be less than twenty-five dollars. The license fee must be paid on or before the original due date for filing the annual report.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch20.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bbb5dfe08c28ea259c3f880bb82b02f461b5b0fb50e7603b2fcc48a17a4601c4",
      "source_url": "https://www.scstatehouse.gov/code/t12c020.php",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SC.llc.tax_regime.qualified_entity_election": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "A qualified entity may elect annually to have tax imposed on the entity's active trade or business income.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-545(G)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) A qualified entity may elect annually under this subsection to have its income taxed on its active trade or business income at the rate provided in subsection (B)(2) imposed on the qualified entity itself. Such elections must be made no later than the due date for filing the applicable income tax return, including any extensions.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SC.llc.treatment.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "S.C. Code § 12-2-25(A)(3)",
          "quote": "(3) \"corporation\" includes a limited liability company or professional or other association taxed for South Carolina income tax purposes as a corporation;",
          "role": "llc_classification",
          "snapshot_path": "rigs/entity-research/corp-lp/snapshots/SC/c2d5f6b32befbd6cbcff20ab2afd98f781448bc400043cf705134850518d00ad.html",
          "source_sha256": "c2d5f6b32befbd6cbcff20ab2afd98f781448bc400043cf705134850518d00ad",
          "source_url": "https://www.scstatehouse.gov/code/t12c002.php"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "Section 12-6-530 uses universal corporate-classification language; no general holding-entity carve-out was located in Chapter 6.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-530",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An income tax is imposed annually at the rate of five percent on the South Carolina taxable income of every corporation, other than those described in Sections 12-6-540 and 12-6-550, and any other entity taxed using the rates of a corporation for federal income tax purposes, transacting, conducting, or doing business within this State or having income within this State, regardless of whether these activities are carried on in intrastate, interstate, or foreign commerce. The terms \"transacting\", \"conducting\", and \"doing business\" include transacting or engaging in any activity for the purpose of financial profit or gain.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SC.llc.treatment.corporate_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "A qualifying holding company may reduce the specified paid-in capital surplus, while § 12-20-50(A) still states the annual fee and minimum.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-20-50(A), (C)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(A) Except as provided in Section 12-20-100, every corporation required to file an annual report shall pay an annual license fee of fifteen dollars plus one dollar for each thousand dollars, or fraction of a thousand dollars, of capital stock and paid-in or capital surplus of the corporation as shown by the records of the corporation on the first day of the taxable year in which the report is filed. In no case may the license fee provided by this section be less than twenty-five dollars. The license fee must be paid on or before the original due date for filing the annual report.\n\n[…]\n\n(C) In addition to the provisions of subsection (B) of this section, a holding company may reduce its paid-in capital surplus by the portion of contributions to capital received from its parent corporation that is directly or indirectly used to finance a subsidiary's expansion costing in excess of one hundred million dollars, which on the date construction started is located in an Economic Impact Zone as defined in Section 12-14-30. A reduction is only allowed pursuant to this subsection for the paid-in capital surplus of the holding company attributable to this contribution to capital for expansion. Additionally, no reduction is allowed unless the expansion is completed within three years of the first contribution to capital received by the holding company, but this three-year limitation may be extended by the Department of Revenue upon written application and good cause shown. Amounts previously excluded in paid-in capital surplus pursuant to this subsection must be included in the first license tax year beginning after the period allowed for the expansion if the expansion is not timely completed.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch20.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "bbb5dfe08c28ea259c3f880bb82b02f461b5b0fb50e7603b2fcc48a17a4601c4",
      "source_url": "https://www.scstatehouse.gov/code/t12c020.php",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SC.llc.treatment.qualified_entity_election": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "operative_rule",
      "display": "Passive investment income is outside the elected entity-level active-trade-or-business base; the statute does not label the entity itself exempt.",
      "fetch_event_id": null,
      "pinpoint": "S.C. Code § 12-6-545(A)(1)(a)-(b), (G)(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) \"Active trade or business income or loss\" means income or loss of an individual, estate, trust, or any other entity except those taxed or exempted from tax pursuant to Sections 12-6-530 through 12-6-550 resulting from the ownership of an interest in a pass-through business. Active trade or business income or loss does not include:\n\n(a)(i) passive investment income as defined in Internal Revenue Code Section 1362(d) generated by a pass-through business and income of the same type regardless of the type of pass-through business generating it; and\n\n(ii) expenses related to passive investment;\n\n(b) capital gains and losses;\n\n[…]\n\n(2) A qualified entity may elect annually under this subsection to have its income taxed on its active trade or business income at the rate provided in subsection (B)(2) imposed on the qualified entity itself. Such elections must be made no later than the due date for filing the applicable income tax return, including any extensions.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SC/snapshots/sc-statehouse-title12-ch6.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "ae31dbc10579d61076ca1b6a48a5a240eab85547ad42df8642e99affbf31909d",
      "source_url": "https://www.scstatehouse.gov/code/t12c006.php",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SD.llc.base_tax_locator.income_tax_on_banks_and_financial_corporations": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The chapter 10-43 rate and minimum are located in SDCL 10-43-4; net-income definition and adjustments are in SDCL 10-43-10.1 through 10-43-10.5.",
      "fetch_event_id": null,
      "pinpoint": "SDCL 10-43-4",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The liability for the tax imposed by this chapter shall arise upon the first day of each tax year and shall be based upon the net income assignable to this state",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
      "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SD.llc.does_not_reach.income_tax_on_banks_and_financial_corporations": {
      "additional_sources": [
        {
          "pinpoint": "SDCL 10-43-10.3(1)",
          "quote": "(1) Dividends received from financial institutions subject to taxation under this chapter, to the extent the dividends were included in taxable income as determined under the Internal Revenue Code;",
          "role": "dividend-subtraction limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
          "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
          "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43"
        },
        {
          "pinpoint": "SDCL 10-43-94",
          "quote": "The State of South Dakota, any political subdivision of the state, and any quasi-governmental organization created by an executive order of the State of South Dakota and any subsidiary of such organization; any nonprofit United States Treasury Community Development Financial Institution, Small Business Administration Certified Development Company, or Regional Revolving Loan Fund; or any commercial club, chamber of commerce, or industrial development corporation formed pursuant to § 9-12-11 or 9-27-37 is exempt from the payment of this tax.",
          "role": "governmental and specified nonprofit exemption boundary",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-10-43-94-entities-exempt.json",
          "source_sha256": "9d74ad8a80d7036a9eb4eadcaa4ddaddf3f208148e5ba3d307ffa26668b94c51",
          "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43-94"
        },
        {
          "pinpoint": "SDCL 10-43-91",
          "quote": "Any corporation, limited liability company, partnership, or other business entity which serves as a trustee or co - trustee for an extended term trust, which trust has a situs for state income tax purposes in the State of South Dakota, is subject to the South Dakota income tax on banks and financial corporations as set forth in chapter 10-43 and if the trustee has not been authorized to accept deposits by the South Dakota director of banking, the comptroller of the currency, the Office of Thrift Supervision, or the Federal Deposit Insurance Corporation, the trustee is deemed to be a financial institution as described in § 10-43-88 and is subject to the minimum tax set forth in § 10-43-90 .",
          "role": "extended-term-trust trustee reach boundary",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-10-43-91-extended-term-trust-trustee.json",
          "source_sha256": "55a1a358bde3a3230d7459f8325e59eedcfee2b456a0e1cd6bc4438f12cc1ca9",
          "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43-91"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "SDCL 10-43-1(10)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "In no event shall a pass-through entity owned in whole or in part, directly or indirectly, by a financial institution subject to tax under this chapter, and formed primarily to facilitate the securitization of assets, be treated as a person for the purpose of subdivision 10-43-1(4);",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-10-43-1-financial-institution-definitions.json",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "c4c1f9258a84b8a33fa283ad150e970d899d4f9bc27f37dd3a60531103e9bca5",
      "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43-1",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SD.llc.effective_period.income_tax_on_banks_and_financial_corporations": {
      "additional_sources": [
        {
          "pinpoint": "SDCL 10-43-10.2 and 10-43-10.3",
          "quote": "10-43-10.2 . Additions to taxable income. Added to taxable income are: (1) Interest or dividend income derived from obligations or securities of states or political subdivisions, or authorities thereof, not included in taxable income as determined under the Internal Revenue Code; (2) All income taxes paid or accrued, as applicable, during the tax year under the provisions of this chapter or under the provisions of any income tax, or franchise or privilege taxes measured by income levied by any other state or political subdivision to the extent that the taxes were deducted to determine federal taxable income; (3) Any amount received as a refund of federal income taxes during the tax year if that amount was previously deducted in determining net income; (4) Dividends received from other corporations to the extent that the dividends have been deducted from net income as determined under the Internal Revenue Code; and (5) Any capital loss from: (a) Liquidating sales within the twelve-month period beginning on the date on which a financial institution adopts a plan of complete liquidation, if all the assets of the financial institution are distributed in complete liquidation, less assets retained to meet claims within the twelve-month period; or (b) The distribution of property in complete liquidation of the financial institution that is subject to federal corporate income taxes pursuant to § 336 of the Internal Revenue Code. Source: SL 1977, ch 96 , § 4(1); SL 1978, ch 83 , § 1; SL 1987, ch 96 , §§ 1, 5; SL 2014, ch 60 , § 1, eff. Jan. 1, 2015; SL 2026, ch 51 , § 2. […] 10-43-10.3 . Subtractions from taxable income. Subtracted from taxable income are: (1) Dividends received from financial institutions subject to taxation under this chapter, to the extent the dividends were included in taxable income as determined under the Internal Revenue Code; (2) Taxes imposed upon the financial institution within the tax year, under the Internal Revenue Code, excluding any taxes imposed under 26 USC § 1374 and 26 USC § 1375; (3) Any interest expense described in §§ 291(e)(1)(B) and 265(b) of the Internal Revenue Code, which interest expense is deductible; (4) Any capital gain from: (a) Liquidating sales within the twelve-month period beginning on the date on which a financial institution adopts a plan of complete liquidation, if all of the assets of the financial institution are distributed in complete liquidation, less assets retained to meet claims within the twelve-month period; or (b) The distribution of property in complete liquidation of the financial institution that is subject to federal corporate income taxes pursuant to § 336 of the Internal Revenue Code; (5) For those financial institutions making an election pursuant to 26 USC § 1362(a) of the United States Internal Revenue Code, as defined by § 10-1-47 , imputed federal income taxes in an amount equal to the taxes that would have been paid on net income as defined in § 10-43-10.1 had the financial institution continued to file its federal tax return without making an election to file pursuant to 26 USC § 1362(a); and (6) For those financial institutions organized as limited liability companies, imputed federal income taxes in an amount equal to the taxes that would have been paid on net income as defined in § 10-43-10.1 had the financial institution elected to file as a subchapter C corporation under the Internal Revenue Code. Source: SL 1977, ch 96 , § 4 (2); SL 1978, ch 83 , § 2; SL 1985, ch 84 ; SL 1987, ch 96 , §§ 2-4; SL 1988, ch 104 ; SL 1997, ch 64 , § 2; SL 2004, ch 289 , § 4; SL 2014, ch 60 , § 2, eff. Jan. 1, 2015; SL 2015, ch 62 , § 11; SL 2016, ch 54 , § 11; SL 2016, ch 62 , § 6; SL 2026, ch 51 , § 3.",
          "role": "complete current adjusted-income sections",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
          "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
          "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43"
        },
        {
          "pinpoint": "SDCL 10-43-1(10)",
          "quote": "(10) \"Person,\" includes individuals, firms, associations, limited liability companies, corporations, estates, fiduciaries, and all entities from which income tax may be due. In no event shall a pass-through entity owned in whole or in part, directly or indirectly, by a financial institution subject to tax under this chapter, and formed primarily to facilitate the securitization of assets, be treated as a person for the purpose of subdivision 10-43-1(4);",
          "role": "current securitization exclusion and source history",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-10-43-1-financial-institution-definitions.json",
          "source_sha256": "c4c1f9258a84b8a33fa283ad150e970d899d4f9bc27f37dd3a60531103e9bca5",
          "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43-1"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The complete current chapter states no operative effective or sunset date for the current holding-income rules or securitization exclusion.",
      "fetch_event_id": null,
      "pinpoint": null,
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
      "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SD.llc.filing_rule.income_tax_on_banks_and_financial_corporations": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "SDCL 10-43-30",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each taxpayer shall file a return for the tax year, and pay any tax imposed by this chapter, within fifteen days after the taxpayer's federal income tax return is due. Any return not filed by the due date or tax not paid by the due date is delinquent and bears penalty and interest as provided in § 10-59-6 .",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
      "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SD.llc.tax_regime.income_tax_on_banks_and_financial_corporations": {
      "additional_sources": [
        {
          "pinpoint": "SDCL 10-43-10.1",
          "quote": "If a financial institution is organized as a limited liability company, the limited liability company shall be treated as a separate corporation for the purpose of this chapter.",
          "role": "express LLC treatment",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
          "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
          "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "SDCL 10-43-2",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An annual tax is hereby imposed on each financial institution doing business in this state or licensed to do business in this state during any part of its tax year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-10-43-2-tax-imposed.json",
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      "source_class": "S1",
      "source_sha256": "323884a9c51b81a0e29dcc6af4f35fb77f08178701f018f825e5f89ef7a08b37",
      "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43-2",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#SD.llc.treatment.income_tax_on_banks_and_financial_corporations": {
      "additional_sources": [
        {
          "pinpoint": "SDCL 10-43-25.5",
          "quote": "Interest, dividends, and net gains from transactions in securities, including stocks, bonds, and all other money markets instruments, shall be included in the numerator specified in § 10-43-25.1 if the financial institution's principal place of business is in South Dakota.",
          "role": "securities-receipt apportionment",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
          "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
          "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43"
        },
        {
          "pinpoint": "SDCL 10-43-10.3(6)",
          "quote": "(6) For those financial institutions organized as limited liability companies, imputed federal income taxes in an amount equal to the taxes that would have been paid on net income as defined in § 10-43-10.1 had the financial institution elected to file as a subchapter C corporation under the Internal Revenue Code.",
          "role": "LLC-specific base subtraction",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
          "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
          "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "SDCL 10-43-10.2(1), (4), 10-43-10.3(1), and 10-43-25.5",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) Interest or dividend income derived from obligations or securities of states or political subdivisions, or authorities thereof, not included in taxable income as determined under the Internal Revenue Code; (2) All income taxes paid or accrued, as applicable, during the tax year under the provisions of this chapter or under the provisions of any income tax, or franchise or privilege taxes measured by income levied by any other state or political subdivision to the extent that the taxes were deducted to determine federal taxable income; (3) Any amount received as a refund of federal income taxes during the tax year if that amount was previously deducted in determining net income; (4) Dividends received from other corporations to the extent that the dividends have been deducted from net income as determined under the Internal Revenue Code; […] (1) Dividends received from financial institutions subject to taxation under this chapter, to the extent the dividends were included in taxable income as determined under the Internal Revenue Code;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/SD/snapshots/sdcl-ch10-43-bank-financial-corporations.json",
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      "source_class": "S1",
      "source_sha256": "a1a22a9594122001e1c74eb0ef9cf1232a6d28efdd2125eb3b02647a487467e1",
      "source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.base_tax_locator.business_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Base and rates: gross sales per location at classification rates under Tenn. Code Ann. §§ 67-4-708 and 67-4-709; amounts are not reproduced here.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Business Tax Manual (June 2026), ch. 4 'Gross Sales' (printed p. 35), n. 53 (Tenn. Code Ann. § 67-4-702(a)(7)); ch. 5 'Tax Rates' (p. 65), n. 133 (Tenn. Code Ann. § 67-4-709)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Gross sales are multiplied by the appropriate classification rate to calculate the tax owed per location.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.base_tax_locator.excise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Base and rate: Tenn. Code Ann. § 67-4-2006 (net earnings, Schedule J adjustments, including deductions for dividends from 80%-owned corporations and taxed pass-through income) and § 67-4-2007; no amounts reproduced.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 1 'Rates and Impositions' > 'Excise Tax' (printed p. 18), nn. 17-19 (Tenn. Code Ann. §§ 67-4-2007, 67-4-2006(a), (b)); ch. 11 Schedule J line 18 (pp. 238-239) and line 25 (p. 247)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Excise tax is based on the taxpayer’s net earnings or net loss for the taxable year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.base_tax_locator.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Base and rate: Tenn. Code Ann. §§ 67-4-2106 and 67-4-2107 (net worth, Schedules F1/F2) and § 67-4-2119 (minimum tax); amounts are not reproduced here.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 9 '3. Franchise Tax Base' (printed p. 152), n. 210 (Tenn. Code Ann. § 67-4-2106(a)); '2. Minimum Franchise Tax' (p. 151), n. 208 (§ 67-4-2119)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The franchise tax base is the taxpayer’s net worth (reported on Schedule F1 or F2).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.does_not_reach.business_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Business Tax Manual (June 2026), ch. 8 'Taxable Sales by Providers of Exempt Services' (printed p. 106); 'Services for Affiliated Entities' (p. 106), nn. 200-201 (Tenn. Code Ann. § 67-4-702(a)(21), (a)(19)); 'Services Sold for a Lump Sum' (p. 105)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Businesses primarily providing services exempt from business tax must still pay business tax on sales of non-exempt tangible personal property and taxable services. These businesses must obtain business licenses and report and pay the business tax on their taxable sales.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.does_not_reach.excise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Tennessee Department of Revenue, FONCE/OME Webinar Q&A responses (published June 2026), Q28 and Q31",
          "quote": "However, if the owner of a pass-through entity that is exempt from franchise and excise taxes is itself a taxable entity that is subject to the tax, then the owner’s excise tax return will include its percentage of pass-through income or loss from the exempt pass-through entity. […] Any entity or individual that is not otherwise subject to the Tennessee excise tax must pay an excise tax equal to 6.5% of the gain from the sale of any asset if any of the following criteria is met (Tenn. Code Ann. § 67-4-2007(f)): […] The entity or individual received the asset through a distribution from a taxpayer within the 12-month period immediately prior to the sale and the taxpayer making the asset distribution ceased to exist prior to the sale; […] The entity or individual received the asset through a merger, liquidation, or any similar transaction involving a taxpayer subject to the Tennessee excise tax during the 12-month period immediately prior to the sale; […] The entity or individual qualified for the obligated member entity exemption provided in § 67-4-2008(a)(9) during the 12-month period immediately prior to the sale; or […] The asset was owned, during the 12-month period immediately prior to the sale, by an affiliate subject to the Tennessee excise tax.",
          "role": "owner-level inclusion and the Tenn. Code Ann. § 67-4-2007(f) gain rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/818ad07c471249dfab65541682a6248335cc3878024ee7c4b1306ff0746c7ecb.pdf",
          "source_sha256": "818ad07c471249dfab65541682a6248335cc3878024ee7c4b1306ff0746c7ecb",
          "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/taxes/fae/QA_Responses_FONCE-OME_Webinar.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 2 'Franchise and Excise Tax Exemptions' (printed pp. 26-27) and 'F&E Exemptions Requiring an Evaluation' items 1, 5 and 6 (pp. 27-40); Tenn. Code Ann. § 67-4-2008 per n. 23, (a)(11)(B) per nn. 45-48; ch. 11 Schedule J line 11 audit procedures (printed p. 235)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "If a taxpayer fails to meet the requirements for the exemption at any time during the taxable period, the taxpayer loses the exemption for the entire taxable period.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.does_not_reach.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 2 'Franchise and Excise Tax Exemptions' (printed pp. 26-27) and 'F&E Exemptions Requiring an Evaluation' items 1, 5 and 6 (pp. 27-40); Tenn. Code Ann. § 67-4-2008 per n. 23, (a)(11)(B) per nn. 45-48",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "If a taxpayer fails to meet the requirements for the exemption at any time during the taxable period, the taxpayer loses the exemption for the entire taxable period.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.effective_period.business_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Business Tax Manual (June 2026), ch. 1 'History' (printed pp. 10-11) and 'Tennessee Works Tax Reform Act of 2023' > '1. Filing and Licensing Thresholds' (p. 11)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective January 1, 2014, per Public Chapter 313, 2013 Acts, the structure of the business tax changed. Significantly, Public Chapter 313 changed the county tax to a uniform state-level tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.effective_period.excise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Tennessee Department of Revenue, FONCE/OME Webinar Q&A responses (published June 2026), Q7",
          "quote": "Effective for tax years ending on or after July 1, 2026, family members are permitted to hold their ownership interests in a FONCE through trusts for the benefit of the family members.",
          "role": "effective-date text for the 2026 FONCE trust-ownership change",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/818ad07c471249dfab65541682a6248335cc3878024ee7c4b1306ff0746c7ecb.pdf",
          "source_sha256": "818ad07c471249dfab65541682a6248335cc3878024ee7c4b1306ff0746c7ecb",
          "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/taxes/fae/QA_Responses_FONCE-OME_Webinar.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 1 'History' (printed p. 17), n. 4 (1999 Tenn. Pub. Ch. 406; Tenn. Code Ann. §§ 67-4-2007, 67-4-2105)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "In 1999, the Tennessee General Assembly passed the Tax Revision and Reform Act that broadened the scope of the franchise and excise tax to all “persons” doing business in Tennessee, including pass-through entities such as limited liability companies (“LLC”) and limited partnerships (“LP”).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.effective_period.franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Tennessee Department of Revenue, FONCE/OME Webinar Q&A responses (published June 2026), Q7",
          "quote": "Effective for tax years ending on or after July 1, 2026, family members are permitted to hold their ownership interests in a FONCE through trusts for the benefit of the family members.",
          "role": "effective-date text for the 2026 FONCE trust-ownership change",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/818ad07c471249dfab65541682a6248335cc3878024ee7c4b1306ff0746c7ecb.pdf",
          "source_sha256": "818ad07c471249dfab65541682a6248335cc3878024ee7c4b1306ff0746c7ecb",
          "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/taxes/fae/QA_Responses_FONCE-OME_Webinar.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 1 'History' (printed p. 17), n. 4 (1999 Tenn. Pub. Ch. 406; Tenn. Code Ann. §§ 67-4-2007, 67-4-2105)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "In 1999, the Tennessee General Assembly passed the Tax Revision and Reform Act that broadened the scope of the franchise and excise tax to all “persons” doing business in Tennessee, including pass-through entities such as limited liability companies (“LLC”) and limited partnerships (“LP”).",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.filing_rule.business_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Business Tax Manual (June 2026), ch. 3 'Registration' (printed p. 28), n. 34; ch. 5 'Classification 3' exempt services (pp. 49-51), n. 105; ch. 8 'Persons with Taxable Sales < $100,000' (p. 108), n. 213 (Tenn. Code Ann. § 67-4-712(d))",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "No business license is needed, and no tax is due unless the business also sells tangible personal property and/or other taxable services. Even if a taxpayer qualifies for one of these exemptions, they still must register and pay business tax on any sales that do not qualify for the exemption",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.filing_rule.excise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Form FAE183, Application for Exemption/Annual Exemption Renewal (RV-R0012201 (11/21)) and instructions: 'Instructions: Application for Exemption' and 'Instructions: Disclosure of Activity'",
          "quote": "Each entity is required to make its initial application for exempt status on this form and must also submit a renewal application annually. […] If the entity does not meet the exemption requirements in any given year, it is taxable on all activities for that year. A completed franchise and excise tax return (FAE170) must be filed electronically with payment of any taxes due by the 15th day of the fourth month following the close of the taxable year.",
          "role": "annual renewal and non-qualifying-year rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/e1c15aae113e73f8f4d4d7b1a858b91a836327994fc808d9f060a9fb6def1545.pdf",
          "source_sha256": "e1c15aae113e73f8f4d4d7b1a858b91a836327994fc808d9f060a9fb6def1545",
          "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/forms/fae/fae183.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 2 exemptions list note (printed p. 27), n. 32; FONCE section (p. 40); ch. 11 Schedule J line 11 audit procedures (printed p. 235)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "* An entity claiming this exemption must file an Application for Exemption/Annual Exemption Renewal (Form FAE183) for the initial and subsequent taxable periods for which the entity is claiming the exemption. This form is due on or before the 15th day of the fourth month following the close of the entity’s taxable period. The Department will grant an extension of time of seven months in which to file the form if the entity makes a valid extension request.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.filing_rule.franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Form FAE183, Application for Exemption/Annual Exemption Renewal (RV-R0012201 (11/21)) and instructions: 'Instructions: Application for Exemption' and 'Instructions: Disclosure of Activity'",
          "quote": "Each entity is required to make its initial application for exempt status on this form and must also submit a renewal application annually. […] If the entity does not meet the exemption requirements in any given year, it is taxable on all activities for that year. A completed franchise and excise tax return (FAE170) must be filed electronically with payment of any taxes due by the 15th day of the fourth month following the close of the taxable year.",
          "role": "annual renewal and non-qualifying-year rule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/e1c15aae113e73f8f4d4d7b1a858b91a836327994fc808d9f060a9fb6def1545.pdf",
          "source_sha256": "e1c15aae113e73f8f4d4d7b1a858b91a836327994fc808d9f060a9fb6def1545",
          "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/forms/fae/fae183.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 2 exemptions list note (printed p. 27), n. 32; FONCE section (p. 40); ch. 9 '2. Minimum Franchise Tax' (p. 151), n. 208",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "* An entity claiming this exemption must file an Application for Exemption/Annual Exemption Renewal (Form FAE183) for the initial and subsequent taxable periods for which the entity is claiming the exemption. This form is due on or before the 15th day of the fourth month following the close of the entity’s taxable period. The Department will grant an extension of time of seven months in which to file the form if the entity makes a valid extension request.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.tax_regime.business_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Business Tax Manual (June 2026), ch. 1 'Brief Business Tax Overview' (printed p. 12) and 'Application' > '2. Imposition' (p. 15); state-level tax per n. 5 (Tenn. Code Ann. § 67-4-704)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Business tax is imposed on a business’s gross sales of tangible personal property and services. The vocations, occupations, businesses, or business activities listed in Tenn. Code Ann. §§ 67-4-708(1)-(5) are taxable privileges subject to Tennessee’s state-level business tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.tax_regime.excise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 1 'Rates and Impositions' > 'Excise Tax' (printed pp. 18-19), n. 20 (Tenn. Code Ann. § 67-4-2007)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Tennessee imposes a 6.5% corporate excise tax on the fiscal year net earnings of all persons engaged in business in Tennessee except nonprofit entities, entities otherwise specifically exempt, and businesses not subject to excise tax, such as sole proprietors.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.tax_regime.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 9 'Franchise Tax' > Overview > '1. Who Must File?' (printed p. 151), n. 205 (Tenn. Code Ann. § 67-4-2105(a)); ch. 1 'Rates and Impositions' (p. 18), n. 15",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The franchise tax is a privilege tax imposed on entities for the privilege of doing business in Tennessee. All entities doing business in Tennessee and having a substantial nexus in Tennessee, except for not-for-profits and other exempt entities, are subject to the franchise tax.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.treatment.business_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Business Tax Manual (June 2026), ch. 8 '10. Banking and Related Functions' (printed p. 100), n. 194 (Tenn. Code Ann. § 67-4-708(3)(C)(i)-(xvi)); '3. Sales of Intangibles' (p. 120)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Services furnished by investment trusts, investment companies, holding companies, and commodity trading companies.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "df949efcb6e1fc6b0c45244d617c2d8ccf08f76762b9b2ab39c7589f07d6e0cd",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.treatment.excise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 2 'Franchise and Excise Tax Exemptions' (printed pp. 26-27), n. 23; ch. 11 Schedule J line 11 audit procedures (printed p. 235)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An entity claiming a tax exemption under Tenn. Code Ann. § 67-4-2008, such as a venture capital fund or family-owned noncorporate entity, is not subject to excise tax and does not file an excise tax return.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TN.llc.treatment.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tennessee Department of Revenue, Franchise and Excise Tax Manual (June 2026), ch. 2 'Franchise and Excise Tax Exemptions' (printed pp. 26-27), n. 23 (Tenn. Code Ann. § 67-4-2008)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There are 17 types of exemptions available to entities that would otherwise be subject to franchise and excise tax. The following exemptions apply to both the franchise and excise taxes.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TN/snapshots/c50/TN/8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830.pdf",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8517e120d79e3a8369e171d1cf19571c6c0145c6c0f0c7effdebae0bae997830",
      "source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TX.llc.base_tax_locator.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Rate and computation: Tax Code § 171.002 (threshold adjusted under § 171.006); taxable margin § 171.101; total revenue § 171.1011; E-Z computation § 171.1016; apportionment § 171.106.",
      "fetch_event_id": null,
      "pinpoint": "Tex. Tax Code § 171.002; ch. 171 capture, Subchapter A, heading 'Sec. 171.002. RATES; COMPUTATION OF TAX.'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 171.002. RATES; COMPUTATION OF TAX.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TX/snapshots/tx-tax-code-ch171-franchise-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "c2991f08337f8ab379317645feb06ae09a49b24b103e07e0e5d7fb900774064e",
      "source_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TX.llc.does_not_reach.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tex. Tax Code §§ 171.0003(a)(1), 171.0003(b), 171.0004(a), (d); ch. 171 capture, Subchapter A",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(b) The income described by Subsection (a)(2) does not include: (1) rent; or (2) income received by a nonoperator from mineral properties under a joint operating agreement if the nonoperator is a member of an affiliated group and another member of that group is the operator under the same joint operating agreement.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TX/snapshots/tx-tax-code-ch171-franchise-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "c2991f08337f8ab379317645feb06ae09a49b24b103e07e0e5d7fb900774064e",
      "source_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TX.llc.effective_period.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tex. Tax Code § 171.0003 source note and § 171.001 source note; ch. 171 capture, Subchapter A",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) income received by a nonoperator from mineral properties under a joint operating agreement if the nonoperator is a member of an affiliated group and another member of that group is the operator under the same joint operating agreement. Amended by: Acts 2006, 79th Leg., 3rd C.S., Ch. 1 (H.B. 3), Sec. 2, eff. January 1, 2008. Acts 2007, 80th Leg., R.S., Ch. 1282 (H.B. 3928), Sec. 3, eff. January 1, 2008.",
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      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TX/snapshots/tx-tax-code-ch171-franchise-tax.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "c2991f08337f8ab379317645feb06ae09a49b24b103e07e0e5d7fb900774064e",
      "source_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TX.llc.filing_rule.franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Comptroller Publication 98-806, Franchise Tax Overview, section 'Franchise Tax Reports and Information Reports'",
          "quote": "However, effective for reports due in 2024, taxable entities with total revenue at or below the no tax due threshold are no longer required to file a Franchise Tax Report but must continue to file an information report each year.",
          "role": "agency_guidance: information report for entities at or below the no-tax-due threshold",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/TX/snapshots/tx-comptroller-98-806-overview.html",
          "source_sha256": "aa1067ffb8bf369853967aa2fc81d8059965202a8ec4789215238a9bcebd366d",
          "source_url": "https://comptroller.texas.gov/taxes/publications/98-806.php"
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      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tex. Tax Code §§ 171.202(a)-(b), 171.2022, 171.203(a)-(b); ch. 171 capture, Subchapter E",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 171.203. PUBLIC INFORMATION REPORT. (a) A corporation, limited liability company, limited partnership, or professional association on which the franchise tax is imposed, regardless of whether the entity is required to pay any tax, shall file a report with the comptroller containing: (1) the name of each corporation, limited liability company, limited partnership, or professional association in which the corporation, limited liability company, limited partnership, or professional association filing the report owns a 10 percent or greater interest and the percentage owned by the entity;",
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      "source_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#TX.llc.tax_regime.franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Franchise tax under Tax Code chapter 171, imposed on each taxable entity that does business in Texas or is chartered or organized in Texas.",
      "fetch_event_id": null,
      "pinpoint": "Tex. Tax Code § 171.001(a); ch. 171 capture, Subchapter A, heading 'Sec. 171.001. TAX IMPOSED.'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 171.001. TAX IMPOSED. (a) A franchise tax is imposed on each taxable entity that does business in this state or that is chartered or organized in this state.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TX/snapshots/tx-tax-code-ch171-franchise-tax.html",
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      "source_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#TX.llc.treatment.franchise_tax": {
      "additional_sources": [
        {
          "pinpoint": "Comptroller Form 05-915 (Rev. 4-26/2), 2026 Texas Franchise Tax Report Information and Instructions: PDF p. 3 'Passive Entities'",
          "quote": "Partnerships (general, limited and limited liability) and trusts (other than business trusts) may qualify as a passive entity and not owe any franchise tax for a reporting period if at least 90% of the entity’s federal gross income (as reported on the entity’s federal income tax return), for the period upon which the tax is based, is from the following sources:",
          "role": "agency_guidance: entity forms that may qualify as passive (LLCs not listed)",
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          "source_sha256": "1e012b86a4632fae17fb3c28e855bd60e20ad417a1b64f9504a367f0d3d53dc1",
          "source_url": "https://comptroller.texas.gov/forms/05-915.pdf"
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      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Tex. Tax Code §§ 171.0002(a), 171.0003(a)(1); ch. 171 capture, Subchapter A",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Sec. 171.0003. DEFINITION OF PASSIVE ENTITY. (a) An entity is a passive entity only if: (1) the entity is a general or limited partnership or a trust, other than a business trust;",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/TX/snapshots/tx-tax-code-ch171-franchise-tax.html",
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      "source_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#UT.llc.base_tax_locator.corporate_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The base, rate, and minimum-tax mechanism for utah corporation franchise tax are located at Utah Code § 59-7-104; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Utah Code § 59-7-104",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Each domestic and foreign corporation, except a corporation that is exempt under Section 59-7-102, shall pay an annual tax to the state based on the corporation's Utah taxable income for the taxable year for the privilege of exercising the corporation's corporate franchise or for the privilege of doing business in the state.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/UT/snapshots/ut-code-title59-ch7.xml",
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      "source_sha256": "eeed76f29d5ee554399bf7e137ed3b695076e0c25fbc3bb21569befb84a5d673",
      "source_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#UT.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The base, rate, and minimum-tax mechanism for utah corporation income tax are located at Utah Code § 59-7-201; no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Utah Code § 59-7-201",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There is imposed upon each corporation, except a corporation that is exempt under Section 59-7-102, a tax upon the corporation's Utah taxable income for the taxable year that is derived from sources within this state other than income for any period that the corporation is required to include in the corporation's tax base under Section 59-7-104.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/UT/snapshots/ut-code-title59-ch7.xml",
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      "source_class": "S1",
      "source_sha256": "eeed76f29d5ee554399bf7e137ed3b695076e0c25fbc3bb21569befb84a5d673",
      "source_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#UT.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The elective PTET base and rate reference are located at Utah Code § 59-10-1403.2(2)(a); no amount is transcribed here.",
      "fetch_event_id": null,
      "pinpoint": "Utah Code § 59-10-1403.2(2)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A pass-through entity that is not a disregarded pass-through entity may elect to pay a tax in an amount equal to the product of: the percentage listed in Subsection 59-10-104(2); and voluntary taxable income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/UT/snapshots/ut-code-title59-ch10.xml",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "f173ff8d0b2a4e1b21c4d411c59bcfdfda8a1ce5caecbab93704d7a04c96fe37",
      "source_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#UT.llc.does_not_reach.corporate_franchise_tax": {
      "additional_sources": [
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          "pinpoint": "Utah Code § 59-7-106(4)(a)",
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        {
          "pinpoint": "Utah Code § 59-7-106(4)(a)",
          "quote": "For purposes of Subsection (1)(l), a taxpayer may not make a subtraction under Subsection (1)(l): if the taxpayer elects to file a worldwide combined report as provided in Section 59-7-403; or for the following: income generated from intangible property; or a capital gain, dividend, interest, rent, royalty, or other similar item that is generated from an asset held for investment and not from a regular business trading activity.",
          "role": "foreign_operating_company_subtraction_limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/UT/snapshots/ut-code-title59-ch7.xml",
          "source_sha256": "eeed76f29d5ee554399bf7e137ed3b695076e0c25fbc3bb21569befb84a5d673",
          "source_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Utah Code § 59-7-309",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "To the extent they constitute nonbusiness income, interest and dividends are allocable to this state if the taxpayer's commercial domicile is in this state.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/UT/snapshots/ut-code-title59-ch7.xml",
      "snapshot_resolved": true,
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      "source_sha256": "eeed76f29d5ee554399bf7e137ed3b695076e0c25fbc3bb21569befb84a5d673",
      "source_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#UT.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Utah Code § 59-10-1402(19)",
          "quote": "\"Voluntary taxable income\" means the sum of a pass-through entity's income that is: attributed to a final pass-through entity taxpayer who is a resident individual unless the income is taxed by another state of the United States, the District of Columbia, or possession of the United States; and business income and nonbusiness income that is derived from or connected with Utah sources; and attributed to a final pass-through entity taxpayer who is a nonresident individual.",
          "role": "elective_tax_base",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/UT/snapshots/ut-code-title59-ch10.xml",
          "source_sha256": "f173ff8d0b2a4e1b21c4d411c59bcfdfda8a1ce5caecbab93704d7a04c96fe37",
          "source_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Utah Code § 59-10-1403.2(2)(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A pass-through entity that is not a disregarded pass-through entity may elect to pay a tax in an amount equal to the product of: the percentage listed in Subsection 59-10-104(2); and voluntary taxable income.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/UT/snapshots/ut-code-title59-ch10.xml",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "f173ff8d0b2a4e1b21c4d411c59bcfdfda8a1ce5caecbab93704d7a04c96fe37",
      "source_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VA.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The corporation-income-tax rate and imposition are located at Va. Code § 58.1-400.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-400",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A tax at the rate of six percent is hereby annually imposed on the Virginia taxable income for each taxable year of every corporation organized under the laws of the Commonwealth and every foreign corporation having income from Virginia sources.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/9c59ea6434a0bdd3568c6b9ee230550f78a5a6b6876911799de3a7bc0844ea99.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9c59ea6434a0bdd3568c6b9ee230550f78a5a6b6876911799de3a7bc0844ea99",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#VA.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective pass-through-entity tax rate and base are located at Va. Code § 58.1-390.3(B).",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-390.3(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "B. A tax at the rate of 5.75 percent is hereby annually imposed on the Virginia taxable income, as calculated pursuant to § 58.1-391 but taking into account only the pro rata or distributive share of each item of income, gain, loss, or deduction attributable to eligible owners, for each taxable year of every pass-through entity that makes the election provided under subsection A.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/fbc0444e18a7f412c8fcfdfe6cf55bd4985257d844173cc43aa197cfb1024e52.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fbc0444e18a7f412c8fcfdfe6cf55bd4985257d844173cc43aa197cfb1024e52",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#VA.llc.base_tax_locator.pass_through_entity_withholding_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The pass-through-entity withholding-tax base and rate are located at Va. Code § 58.1-486.2(B)(1).",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-486.2(B)(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "B. 1. The amount of withholding tax payable by any pass-through entity under this article shall be equal to five percent of the nonresident owner's share of income from Virginia sources of all nonresident owners as determined under this chapter, which may lawfully be taxed by the Commonwealth and which is allocable to a nonresident owner.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/b527faf0aaf1d2657e78a397e01327655300f9192d25337b2cb31a76b5e492e3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b527faf0aaf1d2657e78a397e01327655300f9192d25337b2cb31a76b5e492e3",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article16.1/",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#VA.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "23VAC10-120-20, Income from Virginia sources, B(2)",
          "quote": "2. A foreign corporation whose only connection with Virginia is the receipt of interest on notes, bonds or other instruments secured by deeds of trust on property located in Virginia will have no payroll or real or tangible personal property located in Virginia. Although the interest may be paid by a Virginia resident, for purposes of the sales factor the gross receipts will not be assigned to Virginia because there is no income producing activity in Virginia. See § 58.1-416 of the Code of Virginia. If the corporation is a financial corporation as defined in § 58.1-418 of the Code of Virginia there would be no costs of performance in Virginia. Therefore, such a corporation would have no income from Virginia sources and, since such a corporation is not required to obtain a certificate of authority, it would not be required to file a Virginia income tax return. See 23VAC10-120-310 . However, if such a corporation acquires real or tangible personal property in Virginia by foreclosure or any other means the corporation will have property (or cost of performance) in Virginia. Therefore the corporation will have income from Virginia sources and be required to file a Virginia income tax return.",
          "role": "foreign-corporation source limit",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/433edd8cc09c4c19befd9901968f8742a93e669a7677523a588dc841427db711.html",
          "source_sha256": "433edd8cc09c4c19befd9901968f8742a93e669a7677523a588dc841427db711",
          "source_url": "https://law.lis.virginia.gov/admincode/title23/agency10/chapter120/section20/"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-402(B)(1)-(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "1. Interest, less related expenses to the extent not deducted in determining federal taxable income, on obligations of any state other than Virginia, or of a political subdivision of any such other state unless created by compact or agreement to which the Commonwealth is a party; 2. Interest or dividends, less related expenses to the extent not deducted in determining federal taxable income, on obligations or securities of any authority, commission or instrumentality of the United States, which the laws of the United States exempt from federal income tax but not from state income taxes;",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/9c59ea6434a0bdd3568c6b9ee230550f78a5a6b6876911799de3a7bc0844ea99.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9c59ea6434a0bdd3568c6b9ee230550f78a5a6b6876911799de3a7bc0844ea99",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VA.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The federal-obligation subtraction excludes interest on federal tax refunds, equipment-purchase contracts, and other normal business transactions.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-322.02(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "1. Income derived from obligations, or on the sale or exchange of obligations, of the United States and on obligations or securities of any authority, commission, or instrumentality of the United States to the extent exempt from state income taxes under the laws of the United States, including, but not limited to, stocks, bonds, treasury bills, and treasury notes but not including interest on refunds of federal taxes, interest on equipment purchase contracts, or interest on other normal business transactions.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/be35d01b72d8fee75679f186246c16a0b3e1af99b915ff93fea4ab4af85d637f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "be35d01b72d8fee75679f186246c16a0b3e1af99b915ff93fea4ab4af85d637f",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article2/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VA.llc.does_not_reach.pass_through_entity_withholding_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Public Document 15-240, Investment Pass-Through Entity",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "The person who manages the investments of an investment pass-through entity will be subject to tax in Virginia if the manager carries on any business in Virginia. In such cases, the manager is required to file the appropriate return. The fact that the manager of an investment pass-through entity is located in Virginia will not cause the income of the investment pass-through entity to be considered income from Virginia sources, regardless of whether the manager is one of the owners of the investment pass-through entity or an unrelated party. […] If the intangible assets of an investment pass-through entity include patents, copyrights, trademarks and similar assets, any royalties or other payments by a corporate owner or its affiliated entities to the investment pass-through entity with respect to such assets may be subject to the addback requirements of Va. Code § 58.1-402 C(8), or the equitable adjustment provisions of Va. Code § 58.1-446.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/va-tax-investment-pte-ruling-15-240.html",
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    "holding_tax:pp-holding-entity-tax#VA.llc.effective_period.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Article 10 states no commencement or sunset date for the 50%-ownership dividend subtraction in Va. Code § 58.1-402(C)(10).",
      "fetch_event_id": null,
      "pinpoint": "Full-text search of Va. Code Title 58.1, Chapter 3, Article 10 (§§ 58.1-400 through 58.1-423)",
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    "holding_tax:pp-holding-entity-tax#VA.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "For taxable years beginning on or after January 1, 2022, a pass-through entity may make the annual election on its timely filed return.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-390.3(A)(2)",
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      "publish_status": "publish_ready",
      "quote": "2. For taxable years beginning on and after January 1, 2022, a pass-through entity may make an annual election, on its timely filed return pursuant to § 58.1-392 , to pay the tax levied by this section at the entity level for the taxable period covered by such return. Such election shall be made on or before the due date for filing the applicable return, including any extensions that have been granted.",
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    "holding_tax:pp-holding-entity-tax#VA.llc.effective_period.pass_through_entity_withholding_tax": {
      "additional_sources": [
        {
          "pinpoint": "Va. Code § 58.1-486.2(G)",
          "quote": "G. Every pass-through entity required to deduct and withhold tax under this section is hereby made liable for the payment of the tax due under this section for taxable years beginning on or after January 1, 2008.",
          "role": "statutory withholding effective period",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/b527faf0aaf1d2657e78a397e01327655300f9192d25337b2cb31a76b5e492e3.html",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The investment-PTE guidance applies to tax years beginning on or after January 1, 2015; statutory PTE withholding liability applies from January 1, 2008.",
      "fetch_event_id": null,
      "pinpoint": "Public Document 15-240, effective-period statement",
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      "publish_status": "publish_ready",
      "quote": "This revision of the guidelines is effective for taxable years beginning on or after January 1, 2015.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/va-tax-investment-pte-ruling-15-240.html",
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    "holding_tax:pp-holding-entity-tax#VA.llc.filing_rule.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-441(A)",
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      "quote": "A. Every corporation organized under the laws of the Commonwealth, or having income from Virginia sources, other than a Subchapter S corporation subject to the return filing requirements of § 58.1-392 , shall make a report to the Department on or before the fifteenth day of the fourth month following the close of its taxable year. Such reports shall be made on forms prescribed by the Department and shall contain such information, including the gross receipts from any business carried on in the Commonwealth and a depreciation schedule of property used in such trade or business, as may be necessary for the proper enforcement of this chapter and be accompanied by a copy of any federal tax return or report filed for such taxable year. The Department shall not require any nonprofit organization created exclusively to assist a law-enforcement official or agency in apprehending and convicting perpetrators of crimes, to report on such returns, or otherwise, the names of individuals or amounts paid to such individuals by the organization for providing information about certain crimes.",
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    "holding_tax:pp-holding-entity-tax#VA.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
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      "display": "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.",
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      "pinpoint": "Va. Code § 58.1-392(A)",
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      "quote": "A. Every pass-through entity doing business in Virginia, or having income from Virginia sources, shall make a return to the Department of Taxation on or before the fifteenth day of the fourth month following the close of its taxable year. Such returns shall be made and filed in the manner prescribed by the Department.",
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      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Public Document 15-240 states that a qualifying investment PTE need not pay the withholding tax or file Form 502.",
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      "quote": "The income from the intangible property held by an investment pass-through entity is not income from Virginia sources, and such entities are not required to pay the pass-through entity withholding tax or file Form 502.",
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      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Virginia annually imposes corporation income tax on every Virginia corporation and every foreign corporation having income from Virginia sources.",
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      "pinpoint": "Va. Code § 58.1-400",
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      "quote": "A tax at the rate of six percent is hereby annually imposed on the Virginia taxable income for each taxable year of every corporation organized under the laws of the Commonwealth and every foreign corporation having income from Virginia sources.",
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      "source_sha256": "9c59ea6434a0bdd3568c6b9ee230550f78a5a6b6876911799de3a7bc0844ea99",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VA.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "Virginia annually taxes the Virginia taxable income attributable to eligible owners of every pass-through entity making the annual election.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-390.3(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "B. A tax at the rate of 5.75 percent is hereby annually imposed on the Virginia taxable income, as calculated pursuant to § 58.1-391 but taking into account only the pro rata or distributive share of each item of income, gain, loss, or deduction attributable to eligible owners, for each taxable year of every pass-through entity that makes the election provided under subsection A.",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fbc0444e18a7f412c8fcfdfe6cf55bd4985257d844173cc43aa197cfb1024e52",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#VA.llc.tax_regime.pass_through_entity_withholding_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-486.2(A)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. For the privilege of doing business in the Commonwealth, a pass-through entity that has taxable income for the taxable year derived from or connected with Virginia sources, any portion of which is allocable to a nonresident owner, shall pay a withholding tax under this section, except as provided in subsection C.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/b527faf0aaf1d2657e78a397e01327655300f9192d25337b2cb31a76b5e492e3.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "b527faf0aaf1d2657e78a397e01327655300f9192d25337b2cb31a76b5e492e3",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article16.1/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VA.llc.treatment.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The LLC remains in the corporation-income-tax regime, but qualifying dividends are subtracted from the federal-taxable-income starting point.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code § 58.1-402(A), (C)(10)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A. For purposes of this article, Virginia taxable income for a taxable year means the federal taxable income and any other income taxable to the corporation under federal law for such year of a corporation adjusted as provided in subsections B, C, D, E, G, H, and I. For a regulated investment company and a real estate investment trust, such term means the \"investment company taxable income\" and \"real estate investment trust taxable income,\" respectively, to which shall be added in each case any amount of capital gains and any other income taxable to the corporation under federal law which shall be further adjusted as provided in subsections B, C, D, E, G, H, and I. […] 10. The amount of any dividends received from corporations in which the taxpaying corporation owns 50 percent or more of the voting stock.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/9c59ea6434a0bdd3568c6b9ee230550f78a5a6b6876911799de3a7bc0844ea99.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "9c59ea6434a0bdd3568c6b9ee230550f78a5a6b6876911799de3a7bc0844ea99",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VA.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "Va. Code § 58.1-322.02(1)-(2)",
          "quote": "In computing Virginia taxable income pursuant to § 58.1-322 , to the extent included in federal adjusted gross income, there shall be subtracted: 1. Income derived from obligations, or on the sale or exchange of obligations, of the United States and on obligations or securities of any authority, commission, or instrumentality of the United States to the extent exempt from state income taxes under the laws of the United States, including, but not limited to, stocks, bonds, treasury bills, and treasury notes but not including interest on refunds of federal taxes, interest on equipment purchase contracts, or interest on other normal business transactions. 2. Income derived from obligations, or on the sale or exchange of obligations, of the Commonwealth or of any political subdivision or instrumentality of the Commonwealth.",
          "role": "incorporated obligation-income subtractions",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/be35d01b72d8fee75679f186246c16a0b3e1af99b915ff93fea4ab4af85d637f.html",
          "source_sha256": "be35d01b72d8fee75679f186246c16a0b3e1af99b915ff93fea4ab4af85d637f",
          "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article2/"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The electing LLC remains subject to PTET, but qualifying U.S.- and Virginia-obligation income is subtracted through the incorporated owner-modification rules.",
      "fetch_event_id": null,
      "pinpoint": "Va. Code §§ 58.1-390.3(D), 58.1-391(A)",
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      "publish_status": "publish_ready",
      "quote": "D. A pass-through entity that elects to pay the tax levied by subsection B shall be eligible for all credits, deductions, or other adjustments to taxable income under § 58.1-391 , provided that a pass-through entity's taxable income shall be adjusted to eliminate any federal deduction for state and local income taxes. […] A. In determining Virginia taxable income of an owner, any modification described in §§ 58.1-322.01 , 58.1-322.02 , 58.1-322.03 , and 58.1-322.04 that relates to an item of pass-through entity income, gain, loss or deduction shall be made in accordance with the owner's distributive share, for federal income tax purposes, of the item to which the modification relates. Where an owner's distributive share of any such item is not included in any category of income, gain, loss or deduction required to be taken into account separately for federal income tax purposes, the owner's distributive share of such item shall be determined in accordance with his distributive share, for federal income tax purposes, of pass-through entity taxable income or loss.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/fbc0444e18a7f412c8fcfdfe6cf55bd4985257d844173cc43aa197cfb1024e52.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "fbc0444e18a7f412c8fcfdfe6cf55bd4985257d844173cc43aa197cfb1024e52",
      "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VA.llc.treatment.pass_through_entity_withholding_tax": {
      "additional_sources": [
        {
          "pinpoint": "Va. Code § 58.1-486.2(A)",
          "quote": "A. For the privilege of doing business in the Commonwealth, a pass-through entity that has taxable income for the taxable year derived from or connected with Virginia sources, any portion of which is allocable to a nonresident owner, shall pay a withholding tax under this section, except as provided in subsection C.",
          "role": "statutory Virginia-source-income condition",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/c50/VA/b527faf0aaf1d2657e78a397e01327655300f9192d25337b2cb31a76b5e492e3.html",
          "source_sha256": "b527faf0aaf1d2657e78a397e01327655300f9192d25337b2cb31a76b5e492e3",
          "source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article16.1/"
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Public Document 15-240, Investment Pass-Through Entity",
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      "publish_status": "publish_ready",
      "quote": "The income from the intangible property held by an investment pass-through entity is not income from Virginia sources, and such entities are not required to pay the pass-through entity withholding tax or file Form 502.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VA/snapshots/va-tax-investment-pte-ruling-15-240.html",
      "snapshot_resolved": true,
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      "source_sha256": "abc3f9fe5eb280ca78ae38a1bd6ce04c7f5775316f9f9a4879c210ea6945f116",
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    "holding_tax:pp-holding-entity-tax#VT.llc.base_tax_locator.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The Corporate Income Tax base and rate schedule are located at 32 V.S.A. § 5832.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5832",
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      "publish_status": "publish_ready",
      "quote": "A tax is imposed for each calendar year, or fiscal year ending during that calendar year, upon the income earned or received in that taxable year by every taxable corporation, reduced by any Vermont net operating loss allowed under section 5888 of this title, such tax being the greater of:",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
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    "holding_tax:pp-holding-entity-tax#VT.llc.base_tax_locator.digital_business_entity_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The Digital Business Entity Franchise Tax base and limits are located at 32 V.S.A. § 5832a(a)–(b).",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5832a(a)",
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      "publish_status": "publish_ready",
      "quote": "There is imposed upon every business entity that qualifies as and has elected to be taxed as a digital business entity an annual franchise tax equal to:",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
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    "holding_tax:pp-holding-entity-tax#VT.llc.base_tax_locator.partnership_llc_minimum_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The partnership and LLC minimum tax is located at 32 V.S.A. § 5921.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5921",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A partnership or a limited liability company that is taxed as a partnership under the Internal Revenue Code and is subject to the provisions of section 5920 of this title shall pay an annual tax of $250.00 to the Commissioner of Taxes on or before the due date prescribed for the filing of the entity’s federal return.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
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    "holding_tax:pp-holding-entity-tax#VT.llc.base_tax_locator.partnership_llc_nonresident_payment": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The nonresident-partner or member payment formula is located at 32 V.S.A. § 5920(c).",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5920(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to each of its nonresident partners or nonresident members, a partnership or limited liability company shall for each taxable period be liable for all income taxes, together with related interest and penalties, imposed on the partner or member by Vermont with respect to the income of the partnership or limited liability company.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#VT.llc.base_tax_locator.s_corporation_minimum_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The S corporation minimum tax is located at 32 V.S.A. § 5915.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5915",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An S corporation that is subject to the provisions of section 5914 of this title shall pay an annual tax of $250.00 to the Commissioner of Taxes on or before the due date prescribed for the filing of S corporation returns under subsection 6072(b) of the Internal Revenue Code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#VT.llc.base_tax_locator.s_corporation_nonresident_payment": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The nonresident-shareholder payment formula is located at 32 V.S.A. § 5914(c).",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5914(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to each of its nonresident shareholders, an S corporation shall for each taxable period be liable for all income taxes, together with related interest and penalties, imposed on the shareholder by Vermont with respect to the income of the S corporation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
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    "holding_tax:pp-holding-entity-tax#VT.llc.does_not_reach.corporate_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Section 5838 states that an electing qualifying digital business entity is not subject to section 5832.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5838",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "A corporation shall not be subject to the tax imposed by section 5832 of this title if the corporation qualifies as and elects to be taxed as a digital business entity for the taxable year.",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.does_not_reach.digital_business_entity_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The regime does not reach a nonelecting entity or one that fails the full-year digital-business-entity conditions.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5811(26)",
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      "publish_status": "publish_ready",
      "quote": "“Digital business entity” means a business entity that, during the entire taxable year: (A) was not a member of an affiliated group or engaged in a unitary business with one or more members of an affiliated group that is subject to Vermont income taxation; did not have any Vermont property, payroll, or sales; and did not perform any activities in this State that would constitute doing business for purposes of income taxation except activities described in subdivisions (15)(C)(i) (fulfillment operations) and (C)(ii) (web page or internet site maintenance) of this section; and (B) used mainly computer, electronic, and telecommunications technologies in its formation and in the conduct of its business meetings, in its interaction with shareholders, members, and partners, in executing any other formal requirements.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.does_not_reach.partnership_llc_minimum_tax": {
      "additional_sources": [
        {
          "pinpoint": "2025 Form BI-471 Instructions",
          "quote": "Investment clubs whose assets do not exceed $20,000 and whose income does not exceed $5,000 are not required to pay the annual entity tax. Attach a copy of the balance sheet or year-end brokerage statement(s).",
          "role": "current_return_instructions",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/02953c80f4745e32ea75b5ce0a02cc09a5ae38866f1c419b86ebf39d5c070873.pdf",
          "source_sha256": "02953c80f4745e32ea75b5ce0a02cc09a5ae38866f1c419b86ebf39d5c070873",
          "source_url": "https://tax.vermont.gov/sites/tax/files/documents/BI-471-Instr-2025.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The tax does not reach a qualifying investment club whose activities and both financial ceilings satisfy section 5921.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5921",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Partnerships whose activities are limited to the maintenance and management of their intangible investments and whose annual investment income does not exceed $5,000.00 and whose total assets are not in excess of $20,000.00 shall be exempt from the tax imposed by this section.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
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      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.does_not_reach.partnership_llc_nonresident_payment": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The complete current section 5920 states no holding- or passive-entity exclusion from subsection 5920(c).",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5920(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to each of its nonresident partners or nonresident members, a partnership or limited liability company shall for each taxable period be liable for all income taxes, together with related interest and penalties, imposed on the partner or member by Vermont with respect to the income of the partnership or limited liability company.",
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      "rendered": "value",
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      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
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      "quote": "An S corporation that is subject to the provisions of section 5914 of this title shall pay an annual tax of $250.00 to the Commissioner of Taxes on or before the due date prescribed for the filing of S corporation returns under subsection 6072(b) of the Internal Revenue Code.",
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    "holding_tax:pp-holding-entity-tax#VT.llc.does_not_reach.s_corporation_nonresident_payment": {
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      "display": "The complete current S-corporation subchapter states no holding- or passive-entity exclusion from subsection 5914(c).",
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      "quote": "With respect to each of its nonresident shareholders, an S corporation shall for each taxable period be liable for all income taxes, together with related interest and penalties, imposed on the shareholder by Vermont with respect to the income of the S corporation.",
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      "display": "The digital-business-entity election that supplies the different treatment took effect January 1, 2010.",
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      "display": "The Digital Business Entity Franchise Tax took effect January 1, 2010.",
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      "quote": "Added 2009, No. 1 (Sp. Sess.), § H.53, eff. Jan. 1, 2010.",
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      "pinpoint": "32 V.S.A. § 5921, history",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "1997, No. 156 (Adj. Sess.), § 37a, eff. April 29, 1998.",
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      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5920, history",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "2023, No. 72, § 20, eff. January 1, 2023.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
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    "holding_tax:pp-holding-entity-tax#VT.llc.effective_period.s_corporation_minimum_tax": {
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      "fetch_event_id": null,
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      "display": "Every taxable corporation must file the Vermont corporate income-tax return by the federal-return due date.",
      "fetch_event_id": null,
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      "quote": "Every corporation that is a taxable corporation, for any taxable year, shall file a Vermont corporate income tax return for that taxable year on or before the date a U.S. income tax return is required to be filed for that year by that corporation under the laws of the United States.",
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      "display": "The franchise tax is reported and paid in the stated corporate-tax manner, with a federal return copy supplied to the Commissioner.",
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      "quote": "The franchise tax under this section shall be reported and paid in the same manner as the tax under subdivision 5832(2)(B) of this title; provided, however, that an electing corporation shall also provide the Commissioner with a copy of its federal tax return.",
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      "quote": "A partnership or limited liability company, which engages in activities in Vermont that would subject a C corporation to the requirement to file a return under section 5862 of this title, shall file with the Commissioner an annual return, in the form prescribed by the Commissioner, on or before the due date prescribed for the filing of the entity’s federal return.",
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      "display": "Corporate Income Tax is imposed on income earned or received by every taxable corporation.",
      "fetch_event_id": null,
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      "quote": "A tax is imposed for each calendar year, or fiscal year ending during that calendar year, upon the income earned or received in that taxable year by every taxable corporation, reduced by any Vermont net operating loss allowed under section 5888 of this title, such tax being the greater of:",
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      "display": "An annual franchise tax is imposed on every business entity that qualifies and elects as a digital business entity.",
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      "quote": "There is imposed upon every business entity that qualifies as and has elected to be taxed as a digital business entity an annual franchise tax equal to:",
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      "display": "A partnership-classified LLC subject to section 5920 must pay the annual minimum tax.",
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      "quote": "A partnership or a limited liability company that is taxed as a partnership under the Internal Revenue Code and is subject to the provisions of section 5920 of this title shall pay an annual tax of $250.00 to the Commissioner of Taxes on or before the due date prescribed for the filing of the entity’s federal return.",
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      "quote": "With respect to each of its nonresident partners or nonresident members, a partnership or limited liability company shall for each taxable period be liable for all income taxes, together with related interest and penalties, imposed on the partner or member by Vermont with respect to the income of the partnership or limited liability company.",
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      "quote": "An S corporation that is subject to the provisions of section 5914 of this title shall pay an annual tax of $250.00 to the Commissioner of Taxes on or before the due date prescribed for the filing of S corporation returns under subsection 6072(b) of the Internal Revenue Code.",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.tax_regime.s_corporation_nonresident_payment": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "An S corporation is liable for Vermont income taxes imposed on nonresident shareholders with respect to its income.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5914(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to each of its nonresident shareholders, an S corporation shall for each taxable period be liable for all income taxes, together with related interest and penalties, imposed on the shareholder by Vermont with respect to the income of the S corporation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.treatment.corporate_income_tax": {
      "additional_sources": [
        {
          "pinpoint": "32 V.S.A. § 5832a(a)",
          "quote": "There is imposed upon every business entity that qualifies as and has elected to be taxed as a digital business entity an annual franchise tax equal to:",
          "role": "alternative_franchise_tax",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
          "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
          "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "A corporation that qualifies and elects as a digital business entity uses the amount determined under the separate Digital Business Entity Franchise Tax provision.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5832(2)(B)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An amount determined in accordance with section 5832a of this title for a corporation that qualifies as and has elected to be taxed as a digital business entity for the taxable year; or",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.treatment.digital_business_entity_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Every qualifying electing business entity is subject to the annual franchise tax; no holding- or passive-entity carveout is stated.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5832a(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "There is imposed upon every business entity that qualifies as and has elected to be taxed as a digital business entity an annual franchise tax equal to:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.treatment.partnership_llc_minimum_tax": {
      "additional_sources": [
        {
          "pinpoint": "2025 Form BI-471 Instructions",
          "quote": "Investment clubs whose assets do not exceed $20,000 and whose income does not exceed $5,000 are not required to pay the annual entity tax. Attach a copy of the balance sheet or year-end brokerage statement(s).",
          "role": "agency_application",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/02953c80f4745e32ea75b5ce0a02cc09a5ae38866f1c419b86ebf39d5c070873.pdf",
          "source_sha256": "02953c80f4745e32ea75b5ce0a02cc09a5ae38866f1c419b86ebf39d5c070873",
          "source_url": "https://tax.vermont.gov/sites/tax/files/documents/BI-471-Instr-2025.pdf"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "A qualifying investment club is exempt from the annual entity tax; the current BI-471 instructions operationalize the same two ceilings.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5921",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Partnerships whose activities are limited to the maintenance and management of their intangible investments and whose annual investment income does not exceed $5,000.00 and whose total assets are not in excess of $20,000.00 shall be exempt from the tax imposed by this section.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.treatment.partnership_llc_nonresident_payment": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Section 5920(c) imposes the nonresident-member payment; the complete section states no holding- or passive-entity carveout.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5920(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to each of its nonresident partners or nonresident members, a partnership or limited liability company shall for each taxable period be liable for all income taxes, together with related interest and penalties, imposed on the partner or member by Vermont with respect to the income of the partnership or limited liability company.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.treatment.s_corporation_minimum_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "Every S corporation subject to section 5914 must pay the annual minimum tax; no holding-entity carveout is stated.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5915",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "An S corporation that is subject to the provisions of section 5914 of this title shall pay an annual tax of $250.00 to the Commissioner of Taxes on or before the due date prescribed for the filing of S corporation returns under subsection 6072(b) of the Internal Revenue Code.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#VT.llc.treatment.s_corporation_nonresident_payment": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative",
      "display": "The rule makes the S corporation liable with respect to each nonresident shareholder; no holding-entity carveout is stated.",
      "fetch_event_id": null,
      "pinpoint": "32 V.S.A. § 5914(c)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "With respect to each of its nonresident shareholders, an S corporation shall for each taxable period be liable for all income taxes, together with related interest and penalties, imposed on the shareholder by Vermont with respect to the income of the S corporation.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/VT/snapshots/c50/VT/881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "881fde8bae9f7556594fae9ad7b4681cf7907dccd6e749a717715d9039d4b034",
      "source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.base_tax_locator.business_and_occupation_tax": {
      "additional_sources": [
        {
          "pinpoint": "DOR 'Investment income' page, 'Apportionment'",
          "quote": "Generally, investment income is subject to business and occupation (B&O) tax under the Service and Other Activities classification.",
          "role": "agency guidance: classification of investment income",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/dor-investment-income.html",
          "source_sha256": "51057a2af806e735524ef6c9e3382c3cf1761c8726614e2f8ab848ded10a99ac",
          "source_url": "https://dor.wa.gov/taxes-rates/business-occupation-tax/investment-income"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Rate sections: RCW 82.04.290(2)(a), service and other activities, the classification the 2025 legislative finding names for nondeductible investment income, and RCW 82.04.2907(1) for royalties.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82.04.290(2)(a); RCW 82.04.2907(1); note 'Finding — Intent — 2025 c 420 s 402' under RCW 82.04.4281; ch. 82.04 RCW full-chapter capture (cite=82.04&full=true, fetched 2026-10-02)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2)(a) Upon every person engaging within this state in any business activity other than or in addition to an activity taxed explicitly under this chapter; as to such persons the amount of tax on account of such activities is equal to the gross income of the business multiplied by the rate of: […] (1) Upon every person engaging within this state in the business of receiving income from royalties, the amount of tax with respect to the business is equal to the gross income from royalties multiplied by the rate of […] The legislature further intends to make it clear that nondeductible investment income is subject to the service and other activities business and occupation tax classification and should be apportioned in accordance with RCW 82.04.462.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.base_tax_locator.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "Rate and base sections: RCW 82A.04.520(1)(a) sets the rate on an electing entity's taxable income; RCW 82A.04.520(3) defines that taxable income.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82A.04.520(1)(a) and (3); ch. 82A.04 RCW full-chapter capture (cite=82A.04&full=true, fetched 2026-10-02), section 'RCW 82A.04.520 Pass-through entity tax election.'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1)(a) Beginning January 1, 2028, a tax is imposed at a rate of […] (3)(a) The taxable income of an electing entity consists of:",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.does_not_reach.business_and_occupation_tax": {
      "additional_sources": [
        {
          "pinpoint": "DOR 'Investments' tax topic, 'Compensation for rendition of services not derived from investments'",
          "quote": "Gross income from rendering services, such as investment advisory services, is generally subject to service and other activities B&O tax. This income is not deductible under RCW 82.04.4281, since it is derived from services rather than from investments.",
          "role": "agency guidance: service income not deductible",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/dor-investments-tax-topic.html",
          "source_sha256": "3e6214ba8420d24b9c749ad233a62afb85c1ee7b394c46bc9a02924b0e0856c6",
          "source_url": "https://dor.wa.gov/forms-publications/publications-subject/tax-topics/investments"
        },
        {
          "pinpoint": "DOR 'Investment income' page, 'Deductible investment income' note",
          "quote": "Note: The incidental investment income deduction is not available to banking, lending, or security businesses as those entities are defined in RCW 82.04.4281.",
          "role": "agency guidance: banking, lending and security businesses",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/dor-investment-income.html",
          "source_sha256": "51057a2af806e735524ef6c9e3382c3cf1761c8726614e2f8ab848ded10a99ac",
          "source_url": "https://dor.wa.gov/taxes-rates/business-occupation-tax/investment-income"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82.04.4281(1)(a), (1)(c), (2), (4); ch. 82.04 RCW full-chapter capture (cite=82.04&full=true, fetched 2026-10-02)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(2) The following are not deductible under either subsection (1)(a) or (3) of this section, or both: (a) Amounts received from loans, except as provided in subsection (1)(c) of this section, or the extension of credit to another, revolving credit arrangements, installment sales, the acceptance of payment over time for goods or services, or any of the foregoing that have been transferred by the originator of the same to an affiliate of the transferor; or (b) Amounts received by a banking, lending, or security business.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.does_not_reach.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Full-text search of chapter 82A.04 RCW section bodies (RCW 82A.04.010-82A.04.800); no holding or passive-entity carve-out located for the pass-through entity tax; broader terms reviewed are listed in the notes",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "",
      "readiness": "ready",
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      "rendered": "value",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.effective_period.business_and_occupation_tax": {
      "additional_sources": [
        {
          "pinpoint": "RCW 82.04.4281 history and notes; RCW 82.04.650 history; notes following RCW 82.04.4292 and RCW 82.04.067; ch. 82.04 RCW full-chapter capture (cite=82.04&full=true, fetched 2026-10-02)",
          "quote": "[2025 c 420 s 402; 2007 c 54 s 9; 2002 c 150 s 2; 1980 c 37 s 2. […] Effective date — 2025 c 420 ss 114, 201, 301, 401, and 402: See note following RCW 82.32.875. […] [2010 1st sp.s. c 23 s 111.] […] \"Parts III and XIII and sections 101 through 106, 108 through 112, 501 through 503, 505, 507, 510 through 514, 516 through 519, 901, 903 through 911, and 1201 of this act are necessary for the immediate preservation of the public peace, health, or safety, or support of the state government and its existing public institutions, and take effect June 1, 2010.\" […] Contingency — Application — 2010 1st sp.s. c 23 ss 102-112: See notes following RCW 82.04.067. […] \"If a court of competent jurisdiction, in a final judgment not subject to appeal, adjudges any provision of section 104(1)(c) of this act unconstitutional or otherwise invalid, Part I of this act is null and void in its entirety.\"",
          "role": "history and effective-date notes for the carve-out sections",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d.html",
          "source_sha256": "8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d",
          "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true"
        },
        {
          "pinpoint": "DOR 'Investment income' page, opening paragraph",
          "quote": "This legislation took effect January Jan. 1, 2026.",
          "role": "agency statement: ESHB 2081 effective date",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/dor-investment-income.html",
          "source_sha256": "51057a2af806e735524ef6c9e3382c3cf1761c8726614e2f8ab848ded10a99ac",
          "source_url": "https://dor.wa.gov/taxes-rates/business-occupation-tax/investment-income"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Note 'Effective date — 2025 c 420 ss 114, 201, 301, 401, and 402' following RCW 82.32.875",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "Effective date — 2025 c 420 ss 114, 201, 301, 401, and 402: \"Sections 114, 201, 301, 401, and 402 of this act take effect January 1, 2026.\" [2025 c 420 s 507.]",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/7fe6d54e431eb021342378ab7df7c93a959419c3b571148ad6456a290a44ccb9.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "7fe6d54e431eb021342378ab7df7c93a959419c3b571148ad6456a290a44ccb9",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.32.875",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.effective_period.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82A.04.520(1)(a), (4)(d) and history; note 'Effect of invalidation of 2026 c 238 s 201' following RCW 82A.04.030; ch. 82A.04 RCW full-chapter capture (cite=82A.04&full=true, fetched 2026-10-02)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1)(a) Beginning January 1, 2028, a tax is imposed at a rate of 9.90 percent of the taxable income of an electing entity for each taxable year in which an election under this section is in effect.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.filing_rule.business_and_occupation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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).",
      "fetch_event_id": null,
      "pinpoint": "RCW 82.32.045(1)-(5), version '(Effective until January 1, 2029.)', and subsection (5)(a) of the version '(Effective January 1, 2029.)' on the same page",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) Except as otherwise provided in this chapter and subsection (6) of this section, payments of the taxes imposed under chapters 82.04, 82.08, 82.12, 82.14, 82.16, and 82.27 RCW, along with reports and returns on forms prescribed by the department, are due monthly within 25 days after the end of the month in which the taxable activities occur.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/4485cb4031d94c4db302950e01bcfe6229cf2adfae7bc60dec33c3598550eb2f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "4485cb4031d94c4db302950e01bcfe6229cf2adfae7bc60dec33c3598550eb2f",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.32.045",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.filing_rule.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82A.04.520(2)(a), (4), (6)(a); ch. 82A.04 RCW full-chapter capture (cite=82A.04&full=true, fetched 2026-10-02), section 'RCW 82A.04.520 Pass-through entity tax election.'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(6)(a) The electing entity shall file an annual return reporting taxable income, tax due, estimated payments, and any other information required by the department in a form and manner required by the department.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.tax_regime.business_and_occupation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82.04.220(1); ch. 82.04 RCW full-chapter capture (cite=82.04&full=true, fetched 2026-10-02), section 'RCW 82.04.220 Business and occupation tax imposed.'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) There is levied and collected from every person that has a substantial nexus with this state, as provided in RCW 82.04.067, a tax for the act or privilege of engaging in business activities. The tax is measured by the application of rates against value of products, gross proceeds of sales, or gross income of the business, as the case may be.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.tax_regime.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82A.04.520(1); ch. 82A.04 RCW full-chapter capture (cite=82A.04&full=true, fetched 2026-10-02), section 'RCW 82A.04.520 Pass-through entity tax election.'",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1)(a) Beginning January 1, 2028, a tax is imposed at a rate of 9.90 percent of the taxable income of an electing entity for each taxable year in which an election under this section is in effect. (b) The tax is paid by the electing entity.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.treatment.business_and_occupation_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82.04.080(1); RCW 82.04.4281(1)(b), (3)(b), (6)(b)(ii); ch. 82.04 RCW full-chapter capture (cite=82.04&full=true, fetched 2026-10-02)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(1) In computing tax under this chapter, a person may deduct the following from the measure of tax: […] (b) Amounts derived as dividends or distributions from the capital account by a parent from its subsidiary entities.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "8b51d68535fc22c19d9ee2e8852b01840a41459789312956e8b844a391b17e4d",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WA.llc.treatment.pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "RCW 82A.04.520(3)(c); Full-text search of chapter 82A.04 RCW section bodies (RCW 82A.04.010-82A.04.800); no holding or passive-entity carve-out located for the pass-through entity tax; broader terms reviewed are listed in the notes",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(c) Guaranteed payments, separately stated items, and investment income is included in taxable income to the same extent these items would be included in a participating owner's individual Washington base income under this chapter.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WA/snapshots/c50/WA/2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f08f53791a01f147830c1d51e7e1b2c510b6497a07974b6b9b18d1b36bec24f",
      "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#WI.llc.base_tax_locator.corporation_franchise_tax": {
      "additional_sources": [
        {
          "evidence_role": "apportionment",
          "pinpoint": "Wis. Stat. § 71.25(5)(a)",
          "quote": "71.25(5)(a) (a) Apportionable income. Except as provided in sub. (6) , corporations engaged in business both within and without this state are subject to apportionment. Income gain or loss from the sources listed in this paragraph is presumed apportionable as unitary or operational income or other income that has a taxable presence in this state. Apportionable income includes all income or loss of corporations, other than nonapportionable income as specified in par. (b) , including, but not limited to, income, gain or loss from the following sources: 71.25(5)(a)1. 1. Sale of inventory. 71.25(5)(a)2. 2. Farms, mines and quarries. 71.25(5)(a)3. 3. Sale of scrap and by-products. 71.25(5)(a)4. 4. Commissions. 71.25(5)(a)5. 5. Sale of real property or tangible personal property used in the production of business income. 71.25(5)(a)6. 6. Royalties from intangible assets. 71.25(5)(a)7. 7. Redemption of securities. 71.25(5)(a)8. 8. Interest on trade accounts and trade notes receivable. 71.25(5)(a)9. 9. Interest and dividends if the operations of the payer are unitary with those of the payee, or if those operations are not unitary but the investment activity from which that income is derived is an integral part of a unitary business and the payer and payee are neither affiliates nor related as parent company and subsidiary. In this subdivision, “investment activity” includes decision making relating to the purchase and sale of stocks and other securities, investing surplus funds and the management and record keeping associated with corporate investments, not including activities of a broker or other agent in maintaining an investment portfolio. 71.25(5)(a)10. 10. Sale of intangible assets if the operations of the company in which the investment was made were unitary with those of the investing company, or if those operations were not unitary but the investment activity from which that gain or loss was derived is an integral part of a unitary business and the companies were neither affiliates nor related as parent company and subsidiary. In this subdivision, “investment activity” has the meaning given under subd. 9.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-25-accepted/WI/adf96e9927c2d5d1fb18ddcb235ea94a4954b69923fe05baa3a7cd1bd8138b86.html",
          "source_sha256": "adf96e9927c2d5d1fb18ddcb235ea94a4954b69923fe05baa3a7cd1bd8138b86",
          "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.25"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Imposition and rate: Wis. Stat. § 71.23(2); Wis. Stat. § 71.27(2); Wisconsin net income and allocation/apportionment: § 71.25.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.27(2)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "71.27(2) (2) The corporation franchise tax imposed under s. 71.23 (2) and measured by Wisconsin net income shall be computed at the rate of 7.9 percent.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-27/WI/2f721ca002a63d928328f7ad8ad2aabf4cfbd653a635f3c422cd384d7026e51c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f721ca002a63d928328f7ad8ad2aabf4cfbd653a635f3c422cd384d7026e51c",
      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WI.llc.base_tax_locator.corporation_income_tax": {
      "additional_sources": [
        {
          "evidence_role": "apportionment",
          "pinpoint": "Wis. Stat. § 71.25(5)(a)",
          "quote": "71.25(5)(a) (a) Apportionable income. Except as provided in sub. (6) , corporations engaged in business both within and without this state are subject to apportionment. Income gain or loss from the sources listed in this paragraph is presumed apportionable as unitary or operational income or other income that has a taxable presence in this state. Apportionable income includes all income or loss of corporations, other than nonapportionable income as specified in par. (b) , including, but not limited to, income, gain or loss from the following sources: 71.25(5)(a)1. 1. Sale of inventory. 71.25(5)(a)2. 2. Farms, mines and quarries. 71.25(5)(a)3. 3. Sale of scrap and by-products. 71.25(5)(a)4. 4. Commissions. 71.25(5)(a)5. 5. Sale of real property or tangible personal property used in the production of business income. 71.25(5)(a)6. 6. Royalties from intangible assets. 71.25(5)(a)7. 7. Redemption of securities. 71.25(5)(a)8. 8. Interest on trade accounts and trade notes receivable. 71.25(5)(a)9. 9. Interest and dividends if the operations of the payer are unitary with those of the payee, or if those operations are not unitary but the investment activity from which that income is derived is an integral part of a unitary business and the payer and payee are neither affiliates nor related as parent company and subsidiary. In this subdivision, “investment activity” includes decision making relating to the purchase and sale of stocks and other securities, investing surplus funds and the management and record keeping associated with corporate investments, not including activities of a broker or other agent in maintaining an investment portfolio. 71.25(5)(a)10. 10. Sale of intangible assets if the operations of the company in which the investment was made were unitary with those of the investing company, or if those operations were not unitary but the investment activity from which that gain or loss was derived is an integral part of a unitary business and the companies were neither affiliates nor related as parent company and subsidiary. In this subdivision, “investment activity” has the meaning given under subd. 9.",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-25-accepted/WI/adf96e9927c2d5d1fb18ddcb235ea94a4954b69923fe05baa3a7cd1bd8138b86.html",
          "source_sha256": "adf96e9927c2d5d1fb18ddcb235ea94a4954b69923fe05baa3a7cd1bd8138b86",
          "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.25"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Imposition and rate: Wis. Stat. § 71.23(1); Wis. Stat. § 71.27(1); Wisconsin net income and allocation/apportionment: § 71.25.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.27(1)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "71.27(1) (1) The taxes to be assessed, levied and collected upon Wisconsin net incomes of corporations shall be computed at the rate of 7.9 percent.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-27/WI/2f721ca002a63d928328f7ad8ad2aabf4cfbd653a635f3c422cd384d7026e51c.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2f721ca002a63d928328f7ad8ad2aabf4cfbd653a635f3c422cd384d7026e51c",
      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#WI.llc.base_tax_locator.economic_development_surcharge": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Section 77.94 sets 3% of corporate gross tax liability or 0.2% of tax-option-corporation net income, subject to a $25 minimum and $9,800 maximum.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 77.94",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "77.94 77.94 Surcharge determination. The surcharge imposed under s. 77.93 is an amount equal to the amount calculated by multiplying gross tax liability for the taxable year of the corporation by 3 percent, or in the case of a tax-option corporation an amount equal to the amount calculated by multiplying net income under s. 71.34 by 0.2 percent, up to a maximum of $9,800, or $25, whichever is greater.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec77-94/WI/6f7c14cf99567411d7818f2cace61f11f666e17df6abfe6d1746ad9b654e8bd1.html",
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      "source_class": "S1",
      "source_sha256": "6f7c14cf99567411d7818f2cace61f11f666e17df6abfe6d1746ad9b654e8bd1",
      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/77.94",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WI.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "evidence_role": "s_corporation_base",
          "pinpoint": "Wis. Stat. § 71.365(4m)(d)1.",
          "quote": "71.365(4m)(d)1. 1. The net income of the tax-option corporation is computed under s. 71.34 (1k) , with the following modifications, and the situs of income shall be determined as if the election was not made:",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-365/WI/15abf7d84e24cb8b439f73d2095b6707bce0e716c4ce598cfe23ed3e0ccb9098.html",
          "source_sha256": "15abf7d84e24cb8b439f73d2095b6707bce0e716c4ce598cfe23ed3e0ccb9098",
          "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.365"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Partnership rate and base: § 71.21(6)(a), (d)1.; tax-option-corporation rate and base: § 71.365(4m)(a), (d)1.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.21(6)(d)1.",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "71.21(6)(d)1. 1. The net income of the partnership is computed under subs. (1) to (5) and the situs of income shall be determined as if the election under par. (a) was not made.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-21/WI/e4ee0ca612a091c68476206193306fe35c4cdba7d2aa86340ee30628f432537d.html",
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      "source_class": "S1",
      "source_sha256": "e4ee0ca612a091c68476206193306fe35c4cdba7d2aa86340ee30628f432537d",
      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WI.llc.does_not_reach.corporation_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.22(1k)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "71.22(1k) (1k) “Corporation” includes corporations, publicly traded partnerships treated as corporations in section 7704 of the internal revenue code, limited liability companies treated as corporations under the internal revenue code, joint stock companies, associations, common law trusts and all other entities treated as corporations under section 7701 of the Internal Revenue Code, unless the context requires otherwise. A single-owner entity that is disregarded as a separate entity under section 7701 of the Internal Revenue Code is disregarded as a separate entity under this chapter, and its owner is subject to the tax on or measured by the entity’s income. “Corporation” does not include any entity that is a qualified subchapter S subsidiary under s. 71.365 (7) .",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-22/WI/6f57163baea1ba6508922ae23cef02d6eed61d744a5fd4194d46aa6b78b9ac51.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f57163baea1ba6508922ae23cef02d6eed61d744a5fd4194d46aa6b78b9ac51",
      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.22",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WI.llc.does_not_reach.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.22(1k)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "71.22(1k) (1k) “Corporation” includes corporations, publicly traded partnerships treated as corporations in section 7704 of the internal revenue code, limited liability companies treated as corporations under the internal revenue code, joint stock companies, associations, common law trusts and all other entities treated as corporations under section 7701 of the Internal Revenue Code, unless the context requires otherwise. A single-owner entity that is disregarded as a separate entity under section 7701 of the Internal Revenue Code is disregarded as a separate entity under this chapter, and its owner is subject to the tax on or measured by the entity’s income. “Corporation” does not include any entity that is a qualified subchapter S subsidiary under s. 71.365 (7) .",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-22/WI/6f57163baea1ba6508922ae23cef02d6eed61d744a5fd4194d46aa6b78b9ac51.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "6f57163baea1ba6508922ae23cef02d6eed61d744a5fd4194d46aa6b78b9ac51",
      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.22",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WI.llc.does_not_reach.economic_development_surcharge": {
      "additional_sources": [
        {
          "evidence_role": "disregarded_entity_rule",
          "pinpoint": "Wis. Stat. § 77.935",
          "quote": "77.935 77.935 Single-owner entities. A single-owner entity that is disregarded as a separate entity under ch. 71 is disregarded as a separate entity under this subchapter. The owner of that entity shall include the information from the entity on the owner’s return under this subchapter.",
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      "display": "The rule excludes an exempt corporation with no reportable unrelated business income; a federally disregarded single-owner entity is not separate under this subchapter.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 77.93(1)",
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      "quote": "77.93 77.93 Applicability. For the privilege of doing business in this state, there is imposed an economic development surcharge on the following entities: 77.93(1) (1) All corporations required to file a return under subch. IV or V of ch. 71 that have at least $4,000,000 in gross receipts from all activities for the taxable year except corporations that are exempt from taxation under s. 71.26 (1) and that have no unrelated business income reportable under s. 71.24 (1m) . The surcharge is imposed on the tax-option corporation, not on its shareholders, except that if a tax-option corporation’s surcharge is delinquent, its shareholders are jointly and severally liable for it.",
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    "holding_tax:pp-holding-entity-tax#WI.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "evidence_role": "s_corporation_consent",
          "pinpoint": "Wis. Stat. § 71.365(4m)(a)",
          "quote": "71.365(4m)(a) (a) If persons who hold more than 50 percent of the shares on the day on which an election under this paragraph is made consent, a corporation that is an S corporation for federal income tax purposes may elect, on or before the due date or extended due date of its return under this chapter, to be taxed at the entity level at a rate of 7.9 percent of net income reportable to this state as described in par. (d) 1. for that taxable year.",
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      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Election requires consent from holders of more than 50% of partnership capital and profits or more than 50% of corporation shares.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.21(6)(a)",
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      "publish_status": "publish_ready",
      "quote": "71.21(6)(a) (a) If persons who, on the day on which an election under this paragraph is made, hold more than 50 percent of the capital and profits of a partnership consent, a partnership that is a partnership for federal income tax purposes may elect, on or before the due date or extended due date of its return under this chapter, to be taxed at the entity level at a rate of 7.9 percent of net income reportable to this state as described in par. (d) 1. for that taxable year.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-21/WI/e4ee0ca612a091c68476206193306fe35c4cdba7d2aa86340ee30628f432537d.html",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "Current § 71.23(2) applies with the 7.9% rate stated in Wis. Stat. § 71.27(2).",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.27(2)",
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      "publish_status": "publish_ready",
      "quote": "71.27(2) (2) The corporation franchise tax imposed under s. 71.23 (2) and measured by Wisconsin net income shall be computed at the rate of 7.9 percent.",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27",
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    "holding_tax:pp-holding-entity-tax#WI.llc.effective_period.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
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      "display": "Current § 71.23(1) applies with the 7.9% rate stated in Wis. Stat. § 71.27(1).",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.27(1)",
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      "quote": "71.27(1) (1) The taxes to be assessed, levied and collected upon Wisconsin net incomes of corporations shall be computed at the rate of 7.9 percent.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-27/WI/2f721ca002a63d928328f7ad8ad2aabf4cfbd653a635f3c422cd384d7026e51c.html",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
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      "display": "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.",
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      "pinpoint": "Wis. Stat. § 77.96(1)-(2)",
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      "quote": "77.96(1) (1) An entity’s taxable year for the surcharge under this subchapter is the same as the entity’s taxable year for the taxes under ch. 71 . 77.96(2) (2) The surcharge under this subchapter is due on the date on which the entity’s return under ch. 71 is due without regard to any extension. 77.96(3) (3) The department of revenue shall levy, enforce and collect the surcharge under this subchapter.",
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      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/77.96",
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    "holding_tax:pp-holding-entity-tax#WI.llc.effective_period.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "evidence_role": "s_corporation_period",
          "pinpoint": "Wis. Stat. § 71.365(4m)(a)",
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      "display": "Each current statutory election applies for the taxable year identified on the entity's timely or timely extended return.",
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      "pinpoint": "Wis. Stat. § 71.21(6)(a)",
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      "quote": "71.21(6)(a) (a) If persons who, on the day on which an election under this paragraph is made, hold more than 50 percent of the capital and profits of a partnership consent, a partnership that is a partnership for federal income tax purposes may elect, on or before the due date or extended due date of its return under this chapter, to be taxed at the entity level at a rate of 7.9 percent of net income reportable to this state as described in par. (d) 1. for that taxable year.",
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      "source_class": "S1",
      "source_sha256": "e4ee0ca612a091c68476206193306fe35c4cdba7d2aa86340ee30628f432537d",
      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
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    "holding_tax:pp-holding-entity-tax#WI.llc.filing_rule.corporation_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A nonexempt corporation files by its federal return due date, without extension, and reports each item of nontaxable income.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.24(1)",
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      "quote": "71.24(1) (1) Filing returns. Every corporation, except a corporation all of whose income is exempt from taxation and except as provided in sub. (1m) , shall furnish to the department a true and accurate statement, on or before the date on which the corporation is required to file for federal income tax purposes, not including any extension, under the Internal Revenue Code, in the manner and form and setting forth the facts the department deems necessary to enforce this chapter. Every corporation that is required to furnish a statement under this subsection and that has income that is not taxable under this subchapter shall include with the corporation’s statement a report that identifies each item of the corporation’s nontaxable income. The statement shall be subscribed by the president, vice president, treasurer, assistant treasurer, chief accounting officer, or any other officer duly authorized so to act. In the case of a return made for a corporation by a fiduciary, the fiduciary shall subscribe the return. The fact that an individual’s name is subscribed on the return shall be prima facie evidence that the individual is authorized to subscribe the return on behalf of the corporation.",
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      "quote": "71.24(1) (1) Filing returns. Every corporation, except a corporation all of whose income is exempt from taxation and except as provided in sub. (1m) , shall furnish to the department a true and accurate statement, on or before the date on which the corporation is required to file for federal income tax purposes, not including any extension, under the Internal Revenue Code, in the manner and form and setting forth the facts the department deems necessary to enforce this chapter. Every corporation that is required to furnish a statement under this subsection and that has income that is not taxable under this subchapter shall include with the corporation’s statement a report that identifies each item of the corporation’s nontaxable income. The statement shall be subscribed by the president, vice president, treasurer, assistant treasurer, chief accounting officer, or any other officer duly authorized so to act. In the case of a return made for a corporation by a fiduciary, the fiduciary shall subscribe the return. The fact that an individual’s name is subscribed on the return shall be prima facie evidence that the individual is authorized to subscribe the return on behalf of the corporation.",
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      "display": "A subject person files an accurate gross-tax-liability statement by the chapter 71 filing deadline, including extensions.",
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      "quote": "77.96(5) (5) Each person subject to a surcharge under s. 77.93 shall, on or before the due date, including extensions, for filing under ch. 71 , file an accurate statement of its gross tax liability. Payments made after the due date under sub. (2) and on or before the due date under this subsection are not delinquent but are subject to interest at the rate of 12 percent per year.",
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      "additional_sources": [
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          "evidence_role": "s_corporation_election_deadline",
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      "quote": "71.23(2) (2) Franchise tax. For the privilege of exercising its franchise, buying or selling lottery prizes if the winning tickets were originally bought in this state or doing business in this state in a corporate capacity, except as provided under sub. (3) , every domestic or foreign corporation, except corporations specified in s. 71.26 (1) , and every nuclear decommissioning trust or reserve fund shall annually pay a franchise tax according to or measured by its entire Wisconsin net income of the preceding taxable year at the rate set forth in s. 71.27 (2) . In addition, except as provided in sub. (3) and s. 71.26 (1) , a corporation that ceases doing business in this state and a nuclear decommissioning trust or reserve fund that is terminated shall pay a special franchise tax according to or measured by its entire Wisconsin net income for the taxable year during which the corporation ceases doing business in this state or the nuclear decommissioning trust or reserve fund is terminated at the rates under s. 71.27 (2) . Every corporation organized under the laws of this state shall be deemed to be residing within this state for the purposes of this franchise tax. All provisions of this chapter and ch. 73 relating to income taxation of corporations shall apply to franchise taxes imposed under this subsection, unless the context requires otherwise. The tax imposed by this subsection on national banking associations shall be in lieu of all taxes imposed by this state on national banking associations to the extent it is not permissible to tax such associations under federal law.",
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          "evidence_role": "current_rate",
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          "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The income tax reaches a corporation not subject to the franchise tax that owns Wisconsin property or has Wisconsin-source or attributable income.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.23(1)",
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      "quote": "71.23(1) (1) Income tax. For the purpose of raising revenue for the state and the counties, cities, villages and towns, there shall be assessed, levied, collected and paid a tax as provided under this chapter on all Wisconsin net incomes of corporations that are not subject to the franchise tax under sub. (2) and that own property within this state; that derive income from sources within this state or from activities that are attributable to this state; or whose business within this state during the taxable year, except as provided under sub. (3) , consists exclusively of foreign commerce, interstate commerce, or both, or that buy or sell lottery prizes if the winning tickets were originally bought in this state; except as exempted under s. 71.26 (1) . This section shall not be construed to prevent or affect the correction of errors or omissions in the assessments of income for former years under s. 71.74 (1) and (2) .",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.23",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#WI.llc.tax_regime.economic_development_surcharge": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 77.93(1)",
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      "quote": "77.93 77.93 Applicability. For the privilege of doing business in this state, there is imposed an economic development surcharge on the following entities: 77.93(1) (1) All corporations required to file a return under subch. IV or V of ch. 71 that have at least $4,000,000 in gross receipts from all activities for the taxable year except corporations that are exempt from taxation under s. 71.26 (1) and that have no unrelated business income reportable under s. 71.24 (1m) . The surcharge is imposed on the tax-option corporation, not on its shareholders, except that if a tax-option corporation’s surcharge is delinquent, its shareholders are jointly and severally liable for it.",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/77.93",
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    "holding_tax:pp-holding-entity-tax#WI.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "evidence_role": "s_corporation_election",
          "pinpoint": "Wis. Stat. § 71.365(4m)(a)",
          "quote": "71.365(4m)(a) (a) If persons who hold more than 50 percent of the shares on the day on which an election under this paragraph is made consent, a corporation that is an S corporation for federal income tax purposes may elect, on or before the due date or extended due date of its return under this chapter, to be taxed at the entity level at a rate of 7.9 percent of net income reportable to this state as described in par. (d) 1. for that taxable year.",
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      "capture_date": "2026-10-03",
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      "display": "An eligible partnership or federal S corporation may elect annual entity-level tax at 7.9% of Wisconsin-reportable net income.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.21(6)(a)",
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      "quote": "71.21(6)(a) (a) If persons who, on the day on which an election under this paragraph is made, hold more than 50 percent of the capital and profits of a partnership consent, a partnership that is a partnership for federal income tax purposes may elect, on or before the due date or extended due date of its return under this chapter, to be taxed at the entity level at a rate of 7.9 percent of net income reportable to this state as described in par. (d) 1. for that taxable year.",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#WI.llc.treatment.corporation_franchise_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The listed holding-income categories are presumed apportionable when the statutory unitary or integral-investment conditions are met.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.25(5)(a)",
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      "publish_status": "publish_ready",
      "quote": "71.25(5)(a) (a) Apportionable income. Except as provided in sub. (6) , corporations engaged in business both within and without this state are subject to apportionment. Income gain or loss from the sources listed in this paragraph is presumed apportionable as unitary or operational income or other income that has a taxable presence in this state. Apportionable income includes all income or loss of corporations, other than nonapportionable income as specified in par. (b) , including, but not limited to, income, gain or loss from the following sources: 71.25(5)(a)1. 1. Sale of inventory. 71.25(5)(a)2. 2. Farms, mines and quarries. 71.25(5)(a)3. 3. Sale of scrap and by-products. 71.25(5)(a)4. 4. Commissions. 71.25(5)(a)5. 5. Sale of real property or tangible personal property used in the production of business income. 71.25(5)(a)6. 6. Royalties from intangible assets. 71.25(5)(a)7. 7. Redemption of securities. 71.25(5)(a)8. 8. Interest on trade accounts and trade notes receivable. 71.25(5)(a)9. 9. Interest and dividends if the operations of the payer are unitary with those of the payee, or if those operations are not unitary but the investment activity from which that income is derived is an integral part of a unitary business and the payer and payee are neither affiliates nor related as parent company and subsidiary. In this subdivision, “investment activity” includes decision making relating to the purchase and sale of stocks and other securities, investing surplus funds and the management and record keeping associated with corporate investments, not including activities of a broker or other agent in maintaining an investment portfolio. 71.25(5)(a)10. 10. Sale of intangible assets if the operations of the company in which the investment was made were unitary with those of the investing company, or if those operations were not unitary but the investment activity from which that gain or loss was derived is an integral part of a unitary business and the companies were neither affiliates nor related as parent company and subsidiary. In this subdivision, “investment activity” has the meaning given under subd. 9.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WI/snapshots/c50/WI/sec71-25-accepted/WI/adf96e9927c2d5d1fb18ddcb235ea94a4954b69923fe05baa3a7cd1bd8138b86.html",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.25",
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    "holding_tax:pp-holding-entity-tax#WI.llc.treatment.corporation_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "The listed holding-income categories are presumed apportionable when the statutory unitary or integral-investment conditions are met.",
      "fetch_event_id": null,
      "pinpoint": "Wis. Stat. § 71.25(5)(a)",
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      "quote": "71.25(5)(a) (a) Apportionable income. Except as provided in sub. (6) , corporations engaged in business both within and without this state are subject to apportionment. Income gain or loss from the sources listed in this paragraph is presumed apportionable as unitary or operational income or other income that has a taxable presence in this state. Apportionable income includes all income or loss of corporations, other than nonapportionable income as specified in par. (b) , including, but not limited to, income, gain or loss from the following sources: 71.25(5)(a)1. 1. Sale of inventory. 71.25(5)(a)2. 2. Farms, mines and quarries. 71.25(5)(a)3. 3. Sale of scrap and by-products. 71.25(5)(a)4. 4. Commissions. 71.25(5)(a)5. 5. Sale of real property or tangible personal property used in the production of business income. 71.25(5)(a)6. 6. Royalties from intangible assets. 71.25(5)(a)7. 7. Redemption of securities. 71.25(5)(a)8. 8. Interest on trade accounts and trade notes receivable. 71.25(5)(a)9. 9. Interest and dividends if the operations of the payer are unitary with those of the payee, or if those operations are not unitary but the investment activity from which that income is derived is an integral part of a unitary business and the payer and payee are neither affiliates nor related as parent company and subsidiary. In this subdivision, “investment activity” includes decision making relating to the purchase and sale of stocks and other securities, investing surplus funds and the management and record keeping associated with corporate investments, not including activities of a broker or other agent in maintaining an investment portfolio. 71.25(5)(a)10. 10. Sale of intangible assets if the operations of the company in which the investment was made were unitary with those of the investing company, or if those operations were not unitary but the investment activity from which that gain or loss was derived is an integral part of a unitary business and the companies were neither affiliates nor related as parent company and subsidiary. In this subdivision, “investment activity” has the meaning given under subd. 9.",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.25",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "A qualifying corporation is subject based on gross receipts from all activities; § 77.93 states no special holding-entity treatment.",
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      "pinpoint": "Wis. Stat. § 77.93(1)",
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      "quote": "77.93 77.93 Applicability. For the privilege of doing business in this state, there is imposed an economic development surcharge on the following entities: 77.93(1) (1) All corporations required to file a return under subch. IV or V of ch. 71 that have at least $4,000,000 in gross receipts from all activities for the taxable year except corporations that are exempt from taxation under s. 71.26 (1) and that have no unrelated business income reportable under s. 71.24 (1m) . The surcharge is imposed on the tax-option corporation, not on its shareholders, except that if a tax-option corporation’s surcharge is delinquent, its shareholders are jointly and severally liable for it.",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "operative_rule",
      "display": "No holding-entity or passive-income carve-out was located in either election subsection; the regime is elective.",
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      "source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
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    "holding_tax:pp-holding-entity-tax#WV.llc.base_tax_locator.corporation_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current corporation net income-tax imposition and rate are located in W. Va. Code §11-24-4(8).",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-24-4(8)",
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      "publish_status": "publish_ready",
      "quote": "(8) In the case of taxable periods beginning on or after January 1, 2014, a tax is hereby imposed for each taxable year on the West Virginia taxable income of every domestic or foreign corporation engaging in business in this state or deriving income from property, activity or other sources in this state, except corporations exempt under section five of this article, at the rate of six and one-half percent: Provided, That the reduction in tax authorized by this subsection shall be suspended for one calendar year subsequent to the occurrence of the suspension of the reduction in tax authorized by subdivision (7) of this section: Provided, however, That the reduction in tax on the first day of any calendar year authorized by this subsection shall be suspended if the combined balance of funds as of June 30 of the preceding year in the Revenue Fund Shortfall Reserve Fund and the Revenue Fund Shortfall Reserve Fund - Part B established in section twenty, article two, chapter eleven-b of this code does not equal or exceed ten percent of the General Revenue Fund budgeted for the fiscal year commencing July 1, of the preceding year.",
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      "source_url": "https://code.wvlegislature.gov/11-24-4/",
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    "holding_tax:pp-holding-entity-tax#WV.llc.base_tax_locator.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The elective entity-level tax's base and rate cross-reference are located in W. Va. Code §11-21-3a(k).",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-21-3a(k)",
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      "quote": "(k) A tax equal to the top marginal rate on individuals under this article on the West Virginia taxable income of an electing pass-through entity that makes the election provided under this section, is hereby annually imposed.",
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      "source_url": "https://code.wvlegislature.gov/11-21-3a/",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "negative_full_text_search",
      "display": "No special statutory limit for holding or passive entities was located in the complete corporation net income tax article.",
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    "holding_tax:pp-holding-entity-tax#WV.llc.does_not_reach.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "W. Va. Code §11-21-3a(f)",
          "quote": "(b) \"Electing pass-through entity\" means a qualifying pass-through entity that elects to be subject to the tax levied under this article for a taxable year. (c) \"Owner\" means a person that is a partner, member, shareholder, or investor in an electing pass-through entity for any portion of the taxable year. (d) \"Income\" means the sum of: (1) The owners’ distributive shares of the income, gain, expense, or loss of an electing pass-through entity for the taxable year, as reported for federal income tax purposes; and (2) The resident owner’s distributive share of the electing pass-through entity’s income or loss not attributable to West Virginia. (e) \"Tax Commissioner\" means the Tax Commissioner of the State of West Virginia or his or her delegate, as provided in §11-1-1 et seq . of this code. (f) \"Pass-through entity\" means any partnership or other business entity that is not subject to tax under §11-24-1 et seq . of this code. (g) \"Entity\" means any person that is not an individual.",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The election is unavailable to a federally disregarded entity, and the pass-through entity definition excludes an entity subject to Article 24 corporation tax.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-21-3a(h)-(j)",
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      "quote": "(h) A pass-through entity that is not a disregarded entity for federal income tax purposes may elect to be subject to the tax levied under this section by filing with the Tax Commissioner a form prescribed by the commissioner making such election on or before the deadline to file the return, as specified in §11-21-51 of this code. Such election applies only to the taxable year for which the election is made and, once made, is irrevocable for that year. (i) For taxable years beginning on and after January 1, 2022, an electing pass-through entity may make an election, in a format and according to such requirements and procedures established by the Tax Commissioner, to pay the tax levied by this article at the entity level for the taxable year. (j) An electing pass-through entity required to file a return under this article shall make an election for the taxable period covered by such return. The election must be made on or before the due date for filing the applicable return, including any extensions that have been granted. Such election applies only to the taxable year for which the election is made and, once made, is irrevocable for that year.",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The current corporation net income-tax paragraph applies to taxable periods beginning on or after January 1, 2014.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-24-4(8)",
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      "publish_status": "publish_ready",
      "quote": "(8) In the case of taxable periods beginning on or after January 1, 2014, a tax is hereby imposed for each taxable year on the West Virginia taxable income of every domestic or foreign corporation engaging in business in this state or deriving income from property, activity or other sources in this state, except corporations exempt under section five of this article, at the rate of six and one-half percent: Provided, That the reduction in tax authorized by this subsection shall be suspended for one calendar year subsequent to the occurrence of the suspension of the reduction in tax authorized by subdivision (7) of this section: Provided, however, That the reduction in tax on the first day of any calendar year authorized by this subsection shall be suspended if the combined balance of funds as of June 30 of the preceding year in the Revenue Fund Shortfall Reserve Fund and the Revenue Fund Shortfall Reserve Fund - Part B established in section twenty, article two, chapter eleven-b of this code does not equal or exceed ten percent of the General Revenue Fund budgeted for the fiscal year commencing July 1, of the preceding year.",
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      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The entity-level election is available for taxable years beginning on and after January 1, 2022.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-21-3a(i)",
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      "quote": "(i) For taxable years beginning on and after January 1, 2022, an electing pass-through entity may make an election, in a format and according to such requirements and procedures established by the Tax Commissioner, to pay the tax levied by this article at the entity level for the taxable year.",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WV/snapshots/c50/WV/d4ccd3a70093aa8b397bdce1477efe49fb818ec1b3508baa767685f06c11e01b.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d4ccd3a70093aa8b397bdce1477efe49fb818ec1b3508baa767685f06c11e01b",
      "source_url": "https://code.wvlegislature.gov/11-21-3a/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WV.llc.filing_rule.corporation_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-24-13(a)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) On or before the fifteenth day of the third month following the close of a taxable year, an income tax return under this article shall be made and filed by or for every corporation subject to the tax imposed by this article: Provided, That for tax years beginning after December 31, 2015, an income tax return under this article shall be made and filed by or for every corporation subject to the tax imposed by this article on or before the fifteenth day of the fourth month following the close of a taxable year.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WV/snapshots/c50/WV/84c5ee434e022dfc2a8fd609b676389cc09f1ce1a11f99aba51b933d34f1c565.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "84c5ee434e022dfc2a8fd609b676389cc09f1ce1a11f99aba51b933d34f1c565",
      "source_url": "https://code.wvlegislature.gov/11-24-13/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WV.llc.filing_rule.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "W. Va. Code §11-21-3a(n)",
          "quote": "(n) The full amount of the tax payable as shown on the return of the electing pass-through entity must be paid to the state within the time allowed for filing the return. In the case of any overpayment of the tax imposed under this section, only the electing pass-through entity may request a refund of the overpayment. In the case of any underpayment of tax imposed under this section, the Tax Commissioner may collect the tax from the electing pass-through entity pursuant to §11-10-1 et seq . of this code: Provided , That shareholders, owners, and partners shall be jointly and severally liable for any underpayment of tax not paid by, or collected from, the pass-through entity.",
          "role": "supporting",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WV/snapshots/c50/WV/d4ccd3a70093aa8b397bdce1477efe49fb818ec1b3508baa767685f06c11e01b.html",
          "source_sha256": "d4ccd3a70093aa8b397bdce1477efe49fb818ec1b3508baa767685f06c11e01b",
          "source_url": "https://code.wvlegislature.gov/11-21-3a/"
        }
      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-21-3a(h)-(j)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(h) A pass-through entity that is not a disregarded entity for federal income tax purposes may elect to be subject to the tax levied under this section by filing with the Tax Commissioner a form prescribed by the commissioner making such election on or before the deadline to file the return, as specified in §11-21-51 of this code. Such election applies only to the taxable year for which the election is made and, once made, is irrevocable for that year. (i) For taxable years beginning on and after January 1, 2022, an electing pass-through entity may make an election, in a format and according to such requirements and procedures established by the Tax Commissioner, to pay the tax levied by this article at the entity level for the taxable year. (j) An electing pass-through entity required to file a return under this article shall make an election for the taxable period covered by such return. The election must be made on or before the due date for filing the applicable return, including any extensions that have been granted. Such election applies only to the taxable year for which the election is made and, once made, is irrevocable for that year.",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "d4ccd3a70093aa8b397bdce1477efe49fb818ec1b3508baa767685f06c11e01b",
      "source_url": "https://code.wvlegislature.gov/11-21-3a/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WV.llc.tax_regime.corporation_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-24-4(8)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(8) In the case of taxable periods beginning on or after January 1, 2014, a tax is hereby imposed for each taxable year on the West Virginia taxable income of every domestic or foreign corporation engaging in business in this state or deriving income from property, activity or other sources in this state, except corporations exempt under section five of this article, at the rate of six and one-half percent: Provided, That the reduction in tax authorized by this subsection shall be suspended for one calendar year subsequent to the occurrence of the suspension of the reduction in tax authorized by subdivision (7) of this section: Provided, however, That the reduction in tax on the first day of any calendar year authorized by this subsection shall be suspended if the combined balance of funds as of June 30 of the preceding year in the Revenue Fund Shortfall Reserve Fund and the Revenue Fund Shortfall Reserve Fund - Part B established in section twenty, article two, chapter eleven-b of this code does not equal or exceed ten percent of the General Revenue Fund budgeted for the fiscal year commencing July 1, of the preceding year.",
      "readiness": "ready",
      "reason_code": null,
      "rendered": "value",
      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WV/snapshots/wvcode-11-24-4.html",
      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "2bcea70226e9d7a7261c9182a4bf2ce979d3d93f3e436f7484be1ee262190128",
      "source_url": "https://code.wvlegislature.gov/11-24-4/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WV.llc.tax_regime.elective_pass_through_entity_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "West Virginia annually imposes tax at the top individual marginal rate on the West Virginia taxable income of an electing pass-through entity.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-21-3a(k)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(k) A tax equal to the top marginal rate on individuals under this article on the West Virginia taxable income of an electing pass-through entity that makes the election provided under this section, is hereby annually imposed.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WV/snapshots/c50/WV/d4ccd3a70093aa8b397bdce1477efe49fb818ec1b3508baa767685f06c11e01b.html",
      "snapshot_resolved": true,
      "source_class": "S1",
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      "source_url": "https://code.wvlegislature.gov/11-21-3a/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WV.llc.treatment.corporation_net_income_tax": {
      "additional_sources": null,
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "The generally applicable corporation net income tax applies; no holding-entity carve-out was located in the complete article.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-24-4(8)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(8) In the case of taxable periods beginning on or after January 1, 2014, a tax is hereby imposed for each taxable year on the West Virginia taxable income of every domestic or foreign corporation engaging in business in this state or deriving income from property, activity or other sources in this state, except corporations exempt under section five of this article, at the rate of six and one-half percent: Provided, That the reduction in tax authorized by this subsection shall be suspended for one calendar year subsequent to the occurrence of the suspension of the reduction in tax authorized by subdivision (7) of this section: Provided, however, That the reduction in tax on the first day of any calendar year authorized by this subsection shall be suspended if the combined balance of funds as of June 30 of the preceding year in the Revenue Fund Shortfall Reserve Fund and the Revenue Fund Shortfall Reserve Fund - Part B established in section twenty, article two, chapter eleven-b of this code does not equal or exceed ten percent of the General Revenue Fund budgeted for the fiscal year commencing July 1, of the preceding year.",
      "readiness": "ready",
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      "snapshot_path": "rigs/entity-research/holding-tax/discovery/WV/snapshots/wvcode-11-24-4.html",
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      "source_sha256": "2bcea70226e9d7a7261c9182a4bf2ce979d3d93f3e436f7484be1ee262190128",
      "source_url": "https://code.wvlegislature.gov/11-24-4/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WV.llc.treatment.elective_pass_through_entity_tax": {
      "additional_sources": [
        {
          "pinpoint": "W. Va. Code §11-21-3a(k)",
          "quote": "(k) A tax equal to the top marginal rate on individuals under this article on the West Virginia taxable income of an electing pass-through entity that makes the election provided under this section, is hereby annually imposed.",
          "role": "supporting",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WV/snapshots/c50/WV/d4ccd3a70093aa8b397bdce1477efe49fb818ec1b3508baa767685f06c11e01b.html",
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      ],
      "capture_date": "2026-10-03",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "W. Va. Code §11-21-3a(d) and complete section search",
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      "publish_status": "publish_ready",
      "quote": "(d) \"Income\" means the sum of: (1) The owners’ distributive shares of the income, gain, expense, or loss of an electing pass-through entity for the taxable year, as reported for federal income tax purposes; and (2) The resident owner’s distributive share of the electing pass-through entity’s income or loss not attributable to West Virginia.",
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      "source_url": "https://code.wvlegislature.gov/11-21-3a/",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WY.llc.base_tax_locator.annual_report_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "The license fee's base and rate are set in W.S. 17-29-209(a); W.S. 17-29-210(a)(iii) provides for the annual fee accompanying the annual report.",
      "fetch_event_id": null,
      "pinpoint": "W.S. 17-29-209(a) (PDF p. 690); W.S. 17-29-210(a)(iii) (PDF p. 691)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "shall pay to the secretary of state in addition to all other statutory taxes and fees a license fee based upon the sum of its capital, property and assets reported […] (iii) An annual fee accompanying the report required in W.S. 17-29-209, due and payable on or before the date of the filing under W.S. 17-29-209;",
      "readiness": "ready",
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      "source_sha256": "f0fd7eb843b83bb60095bad496330f8dfd46ff7051dff8d1bec822650a3671f6",
      "source_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
      "table": "holding_tax"
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    "holding_tax:pp-holding-entity-tax#WY.llc.does_not_reach.annual_report_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "Full-text search of W.S. 17-29-101 through 17-29-1105 (Title 17 PDF pp. 672-745) plus the Secretary of State Annual Report and License Tax Rules and Appendix 1 worksheet; no holding or passive carve-out located",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": null,
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      "source_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WY.llc.effective_period.annual_report_license_fee": {
      "additional_sources": [
        {
          "pinpoint": "Secretary of State Business Division Filing Fee Schedule Effective July 1st, 2026, p. 1, 'Limited Liability Companies' block",
          "quote": "Business Division Filing Fee Schedule Effective July 1st, 2026 […] Limited Liability Companies: […] *Annual Report License tax is $60 or two-tenths of one mill on the dollar ($.0002) whichever is greater based on the company's assets located and employed in the state of Wyoming.",
          "role": "agency_fee_schedule",
          "snapshot_path": "rigs/entity-research/holding-tax/discovery/WY/snapshots/sos-businessfees.pdf",
          "source_sha256": "bbaefb74edfa885839a01317dfb79006e81d200e47b6d876ded223eadc97bc8b",
          "source_url": "https://sos.wyo.gov/business/docs/businessfees.pdf"
        }
      ],
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "W.S. 17-29-1103 (Title 17 PDF p. 743) and 17-29-1104 (PDF p. 744); SoS Business Division Filing Fee Schedule Effective July 1st, 2026, p. 1 (Limited Liability Companies)",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "17-29-1103. Application to existing domestic limited liability companies. (a) Except as provided in subsection (b) of this section, this chapter applies to domestic limited liability companies in existence on July 1, 2010 that were organized under any general statute of this state providing for organization of limited liability companies. (b) For limited liability companies organized in Wyoming prior to the effective date of this chapter, the management provisions contained in former W.S. 17-15-116, the division of profits provisions contained in former W.S. 17-15-119, the distribution of assets upon dissolution provisions contained in former W.S. 17-15-126 and the stated term provisions contained in former W.S. 17-15-107(a)(ii) are continued for a period of four (4) years from the effective date of this chapter unless the limited liability company amends its articles of organization to provide otherwise. […] 17-29-1104. Applications to qualified foreign limited liability companies. A foreign limited liability company authorized to transact business in this state on the effective date of this chapter is subject to this chapter but is not required to obtain a new certificate of authority to transact business under this chapter.",
      "readiness": "ready",
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      "snapshot_resolved": true,
      "source_class": "S1",
      "source_sha256": "f0fd7eb843b83bb60095bad496330f8dfd46ff7051dff8d1bec822650a3671f6",
      "source_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WY.llc.filing_rule.annual_report_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "W.S. 17-29-209(a), (c), Title 17 PDF pp. 689-690",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Every limited liability company organized under the laws of this state and every foreign limited liability company which obtains a certificate of authority to transact and carry on business within this state shall file with the secretary of state on or before the first day of the month of organization of every year a certification, under the penalty of perjury, by its treasurer or other fiscal agent setting forth its capital, property and assets located and employed in the state of Wyoming. The statement shall give the address of its principal office. […] (c) Financial information in the annual report shall be current as of the end of the limited liability company's or foreign limited liability company's fiscal year immediately preceding the date the annual report is executed on behalf of the company. All other information in the annual report shall be current as of the date the annual report is executed on behalf of the company.",
      "readiness": "ready",
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      "rendered": "value",
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      "source_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WY.llc.tax_regime.annual_report_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "W.S. 17-29-209(a), Wyoming Limited Liability Company Act (Title 17 ch. 29 art. 2), section heading 'Annual report for secretary of state.', wyoleg.gov compressed Title 17 PDF pp. 689-690",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "On or before the first day of the month of organization of every year the limited liability company or foreign limited liability company shall pay to the secretary of state in addition to all other statutory taxes and fees a license fee based upon the sum of its capital, property and assets reported, of sixty dollars ($60.00) or two-tenths of one mill on the dollar ($.0002), whichever is greater.",
      "readiness": "ready",
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      "source_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
      "table": "holding_tax"
    },
    "holding_tax:pp-holding-entity-tax#WY.llc.treatment.annual_report_license_fee": {
      "additional_sources": null,
      "capture_date": "2026-10-02",
      "claim_type": "primary",
      "display": "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.",
      "fetch_event_id": null,
      "pinpoint": "W.S. 17-29-209(a)-(b), Title 17 PDF pp. 689-690",
      "public_reason": null,
      "publish_status": "publish_ready",
      "quote": "(a) Every limited liability company organized under the laws of this state and every foreign limited liability company which obtains a certificate of authority to transact and carry on business within this state shall file with the secretary of state on or before the first day of the month of organization of every year a certification, under the penalty of perjury, by its treasurer or other fiscal agent setting forth its capital, property and assets located and employed in the state of Wyoming. […] On or before the first day of the month of organization of every year the limited liability company or foreign limited liability company shall pay to the secretary of state in addition to all other statutory taxes and fees a license fee based upon the sum of its capital, property and assets reported […] (b) The provisions of subsection (a) of this section shall be modified as follows: (i) Any limited liability company or foreign limited liability company engaged in the public calling of carrying goods, passengers or information interstate is not required to comply with the provisions of subsection (a) of this section except to the extent of capital, property and assets used in intrastate business in this state; (ii) The value of all mines and mining claims from which gold, silver and other precious metals, soda, saline, coal, mineral oil or other valuable deposit, is or shall be produced is deemed equivalent to the assessed value of the gross product thereof, for the previous year; (iii) […] The assessed value of any property shall be its […] actual value.",
      "readiness": "ready",
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      "rendered": "value",
      "snapshot_path": "rigs/entity-research/corp-lp/snapshots/WY/f0fd7eb843b83bb60095bad496330f8dfd46ff7051dff8d1bec822650a3671f6.pdf",
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      "source_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
      "table": "holding_tax"
    }
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  "last_updated": "2026-10-06",
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  "tables": {
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      "field_definitions": {
        "base_tax_locator.affected_business_entity_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.affected_business_entity_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.affected_business_entity_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.affected_business_entity_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.affected_business_entity_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
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      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-01",
      "rows": [
        {
          "cells": {
            "base_tax_locator.affected_business_entity_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3026B/",
              "cell_locator": "ID.llc.base_tax_locator.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.affected_business_entity_tax",
              "value": "Section 63-3026B(3) locates the Idaho-source base, chapter modifications, and corporate-rate cross-reference; no amount is transcribed here."
            },
            "does_not_reach.affected_business_entity_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3027/",
              "cell_locator": "ID.llc.does_not_reach.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.affected_business_entity_tax",
              "value": "The stated interest/dividend allocation reaches Idaho-commercial-domicile income unless apportionable; §63-3026B separately excludes an exempt member's apportioned share."
            },
            "effective_period.affected_business_entity_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3026B/",
              "cell_locator": "ID.llc.effective_period.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.affected_business_entity_tax",
              "value": "A partnership or S corporation may make a separate ABE election for any taxable year."
            },
            "filing_rule.affected_business_entity_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3026B/",
              "cell_locator": "ID.llc.filing_rule.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.affected_business_entity_tax",
              "value": "An ABE pays by the fifteenth day of the fourth month after the taxable year closes; a separate election is required each year."
            },
            "tax_regime.affected_business_entity_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3026B/",
              "cell_locator": "ID.llc.tax_regime.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.affected_business_entity_tax",
              "value": "An electing partnership or S corporation transacting business in Idaho pays entity-level tax on its Idaho-source affected-business-entity income."
            },
            "treatment.affected_business_entity_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3026B/",
              "cell_locator": "ID.llc.treatment.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.affected_business_entity_tax",
              "value": "The complete ABE-tax section states no holding or passive-entity exemption or different treatment."
            }
          },
          "jurisdiction": "ID",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3026B/",
          "state": "Idaho"
        },
        {
          "cells": {
            "base_tax_locator.affected_business_entity_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
              "cell_locator": "MO.llc.base_tax_locator.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.affected_business_entity_tax",
              "value": "The partnership and S-corporation ABE bases and rate reference are located at § 143.436.3-.4."
            },
            "does_not_reach.affected_business_entity_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
              "cell_locator": "MO.llc.does_not_reach.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.affected_business_entity_tax",
              "value": "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."
            },
            "effective_period.affected_business_entity_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
              "cell_locator": "MO.llc.effective_period.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.affected_business_entity_tax",
              "value": "The affected-business-entity tax applies only to tax years ending on or after December 31, 2022."
            },
            "filing_rule.affected_business_entity_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
              "cell_locator": "MO.llc.filing_rule.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.affected_business_entity_tax",
              "value": "An ABE files an affected-business-entity tax return for each subject year, and a separate prescribed election is required for every tax year."
            },
            "tax_regime.affected_business_entity_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
              "cell_locator": "MO.llc.tax_regime.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.affected_business_entity_tax",
              "value": "Missouri imposes the SALT Parity Act tax on each electing affected partnership or S corporation doing business in the state."
            },
            "treatment.affected_business_entity_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
              "cell_locator": "MO.llc.treatment.affected_business_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.affected_business_entity_tax",
              "value": "The ABE base uses holding-receipt source allocation and removes another ABE's distributive Missouri net income, or adds its distributive Missouri net loss."
            }
          },
          "jurisdiction": "MO",
          "last_checked": "2026-10-03",
          "official_source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.436",
          "state": "Missouri"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-02": {
      "field_definitions": {
        "base_tax_locator.affiliated_finance_company_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.affiliated_finance_company_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.affiliated_finance_company_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.affiliated_finance_company_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.affiliated_finance_company_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.affiliated_finance_company_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-02",
      "rows": [
        {
          "cells": {
            "base_tax_locator.affiliated_finance_company_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c063/index.html",
              "cell_locator": "DE.llc.base_tax_locator.affiliated_finance_company_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.affiliated_finance_company_tax",
              "value": "The tax table is in 30 Del. C. § 6303(a), and the capital base it is measured by is defined in § 6303(b)."
            },
            "does_not_reach.affiliated_finance_company_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c063/index.html",
              "cell_locator": "DE.llc.does_not_reach.affiliated_finance_company_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.affiliated_finance_company_tax",
              "value": "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."
            },
            "effective_period.affiliated_finance_company_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c063/index.html",
              "cell_locator": "DE.llc.effective_period.affiliated_finance_company_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.affiliated_finance_company_tax",
              "value": "The license requirement applies to carrying on business as an affiliated finance company after May 1, 1981 (30 Del. C. § 6302)."
            },
            "filing_rule.affiliated_finance_company_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c063/index.html",
              "cell_locator": "DE.llc.filing_rule.affiliated_finance_company_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.affiliated_finance_company_tax",
              "value": "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."
            },
            "tax_regime.affiliated_finance_company_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c063/index.html",
              "cell_locator": "DE.llc.tax_regime.affiliated_finance_company_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.affiliated_finance_company_tax",
              "value": "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."
            },
            "treatment.affiliated_finance_company_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c063/index.html",
              "cell_locator": "DE.llc.treatment.affiliated_finance_company_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.affiliated_finance_company_tax",
              "value": "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)."
            }
          },
          "jurisdiction": "DE",
          "last_checked": "2026-10-02",
          "official_source_url": "https://delcode.delaware.gov/title30/c063/index.html",
          "state": "Delaware"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-03": {
      "field_definitions": {
        "base_tax_locator.alternative_corporate_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.alternative_corporate_income_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.alternative_corporate_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.alternative_corporate_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.alternative_corporate_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.alternative_corporate_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-03",
      "rows": [
        {
          "cells": {
            "base_tax_locator.alternative_corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0030/0150-0310-0040-0030.html",
              "cell_locator": "MT.llc.base_tax_locator.alternative_corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.alternative_corporate_income_tax",
              "value": "The alternative-tax rate and source rules are in §15-31-403; §15-31-406 incorporates the corporate income and deduction provisions."
            },
            "does_not_reach.alternative_corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0140/0150-0310-0010-0140.html",
              "cell_locator": "MT.llc.does_not_reach.alternative_corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.alternative_corporate_income_tax",
              "value": "The RIC deduction excludes dividends attributable to income not taxed when earned and disallows a dividends-received deduction; the NOL deduction is also unavailable."
            },
            "effective_period.alternative_corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0030/0150-0310-0040-0030.html",
              "cell_locator": "MT.llc.effective_period.alternative_corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.alternative_corporate_income_tax",
              "value": "The alternative corporate income tax applies to taxable years beginning after December 31, 1970."
            },
            "filing_rule.alternative_corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0110/0150-0310-0010-0110.html",
              "cell_locator": "MT.llc.filing_rule.alternative_corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.alternative_corporate_income_tax",
              "value": "A corporation files an accurate net-income return for each tax period under the stated calendar- or fiscal-year due-date rule."
            },
            "tax_regime.alternative_corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0030/0150-0310-0040-0030.html",
              "cell_locator": "MT.llc.tax_regime.alternative_corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.alternative_corporate_income_tax",
              "value": "The alternative corporate income tax reaches every corporation outside part 1 that is taxable under an income tax and has Montana-source net income."
            },
            "treatment.alternative_corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0140/0150-0310-0010-0140.html",
              "cell_locator": "MT.llc.treatment.alternative_corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.alternative_corporate_income_tax",
              "value": "A qualifying regulated investment company remains within the corporate regime but receives the stated dividends-paid deduction with express exclusions."
            }
          },
          "jurisdiction": "MT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0040/section_0030/0150-0310-0040-0030.html",
          "state": "Montana"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-04": {
      "field_definitions": {
        "base_tax_locator.annual_franchise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.annual_franchise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.annual_franchise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.annual_franchise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.annual_franchise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.annual_franchise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-04",
      "rows": [
        {
          "cells": {
            "base_tax_locator.annual_franchise_tax": {
              "cell_citation_url": "https://www.arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2023R%2FPublic%2FACT459.pdf",
              "cell_locator": "AR.llc.base_tax_locator.annual_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.annual_franchise_tax",
              "value": "The LLC minimum-franchise-tax rule is located at Ark. Code Ann. § 26-54-104(8)."
            },
            "does_not_reach.annual_franchise_tax": {
              "cell_citation_url": "https://www.sos.arkansas.gov/uploads/bcs/LLC1_FT_2026.pdf",
              "cell_locator": "AR.llc.does_not_reach.annual_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.annual_franchise_tax",
              "value": "The current LLC report identifies only nonprofit/federally income-tax-exempt corporations and Uniform Partnership or Limited Partnership Act organizations as exempt."
            },
            "effective_period.annual_franchise_tax": {
              "cell_citation_url": "https://www.sos.arkansas.gov/uploads/bcs/LLC1_FT_2026.pdf",
              "cell_locator": "AR.llc.effective_period.annual_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.annual_franchise_tax",
              "value": "The current form is the 2026 annual LLC franchise-tax report and states a May 1, 2026 due date."
            },
            "filing_rule.annual_franchise_tax": {
              "cell_citation_url": "https://www.sos.arkansas.gov/uploads/bcs/LLC1_FT_2026.pdf",
              "cell_locator": "AR.llc.filing_rule.annual_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.annual_franchise_tax",
              "value": "LLCs may file through the Secretary of State website or on paper, and all companies must comply with the May 1 due date."
            },
            "tax_regime.annual_franchise_tax": {
              "cell_citation_url": "https://www.arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2023R%2FPublic%2FACT459.pdf",
              "cell_locator": "AR.llc.tax_regime.annual_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.annual_franchise_tax",
              "value": "Unless exempted under § 26-54-105, every entity within the chapter's corporation definition files an annual report and pays annual franchise tax."
            },
            "treatment.annual_franchise_tax": {
              "cell_citation_url": "https://www.arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2023R%2FPublic%2FACT459.pdf",
              "cell_locator": "AR.llc.treatment.annual_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.annual_franchise_tax",
              "value": "An LLC is taxed under the universal annual-franchise-tax rule and pays the minimum franchise tax; no separate holding-company treatment was located."
            }
          },
          "jurisdiction": "AR",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2023R%2FPublic%2FACT459.pdf",
          "state": "Arkansas"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-05": {
      "field_definitions": {
        "base_tax_locator.annual_llc_charge": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.annual_llc_charge": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.annual_llc_charge": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.annual_llc_charge": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.annual_llc_charge": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.annual_llc_charge": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-05",
      "rows": [
        {
          "cells": {
            "base_tax_locator.annual_llc_charge": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
              "cell_locator": "RI.llc.base_tax_locator.annual_llc_charge",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.annual_llc_charge",
              "value": "The annual-charge base is located in §7-16-67(c)(2), which cross-references the corporate minimum in §44-11-2(e); no amount is transcribed here."
            },
            "does_not_reach.annual_llc_charge": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
              "cell_locator": "RI.llc.does_not_reach.annual_llc_charge",
              "note": "The checked source text does not state the row-specific detail needed for this value. Each row's own reason is the line under its Unknown badge.",
              "publish_status": "typed_unknown",
              "source_field": "does_not_reach.annual_llc_charge",
              "value": "unknown",
              "visible_subline": "The checked source text does not state the row-specific detail needed for this value. Each row's own reason is the line under its Unknown badge."
            },
            "effective_period.annual_llc_charge": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
              "cell_locator": "RI.llc.effective_period.annual_llc_charge",
              "publish_status": "publish_ready",
              "source_field": "effective_period.annual_llc_charge",
              "value": "The current LLC return rule applies for tax years on or after January 1, 2016 (§7-16-67(b))."
            },
            "filing_rule.annual_llc_charge": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
              "cell_locator": "RI.llc.filing_rule.annual_llc_charge",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.annual_llc_charge",
              "value": "The LLC return is due when its federal return is due, without regard to extension (§7-16-67(b))."
            },
            "tax_regime.annual_llc_charge": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
              "cell_locator": "RI.llc.tax_regime.annual_llc_charge",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.annual_llc_charge",
              "value": "A Rhode Island LLC not treated as a corporation federally must pay the annual charge described in §7-16-67(c)(2)."
            },
            "treatment.annual_llc_charge": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
              "cell_locator": "RI.llc.treatment.annual_llc_charge",
              "publish_status": "publish_ready",
              "source_field": "treatment.annual_llc_charge",
              "value": "Rhode Island's annual charge reaches every LLC not taxed as a corporation, with no holding or passive-activity exception in the LLC Act."
            }
          },
          "jurisdiction": "RI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
          "state": "Rhode Island"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-06": {
      "field_definitions": {
        "base_tax_locator.annual_llc_filing_fee": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.annual_llc_filing_fee": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.annual_llc_filing_fee": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.annual_llc_filing_fee": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.annual_llc_filing_fee": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.annual_llc_filing_fee": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-06",
      "rows": [
        {
          "cells": {
            "base_tax_locator.annual_llc_filing_fee": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
              "cell_locator": "NY.llc.base_tax_locator.annual_llc_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.annual_llc_filing_fee",
              "value": "The LLC filing-fee measure and schedule are located in N.Y. Tax Law §658(c)(3)(A)-(B)."
            },
            "does_not_reach.annual_llc_filing_fee": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
              "cell_locator": "NY.llc.does_not_reach.annual_llc_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.annual_llc_filing_fee",
              "value": "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."
            },
            "effective_period.annual_llc_filing_fee": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
              "cell_locator": "NY.llc.effective_period.annual_llc_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "effective_period.annual_llc_filing_fee",
              "value": "The provision states that the current minimum and disregarded-LLC filing fee apply for taxable years beginning in 2008 and thereafter."
            },
            "filing_rule.annual_llc_filing_fee": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
              "cell_locator": "NY.llc.filing_rule.annual_llc_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.annual_llc_filing_fee",
              "value": "The filing-fee payment is due by the fifteenth day of the third month following the close of the taxable year."
            },
            "tax_regime.annual_llc_filing_fee": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
              "cell_locator": "NY.llc.tax_regime.annual_llc_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.annual_llc_filing_fee",
              "value": "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."
            },
            "treatment.annual_llc_filing_fee": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
              "cell_locator": "NY.llc.treatment.annual_llc_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "treatment.annual_llc_filing_fee",
              "value": "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."
            }
          },
          "jurisdiction": "NY",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.nysenate.gov/legislation/laws/TAX/658",
          "state": "New York"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-07": {
      "field_definitions": {
        "base_tax_locator.annual_report_license_fee": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.annual_report_license_fee": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.annual_report_license_fee": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.annual_report_license_fee": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.annual_report_license_fee": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.annual_report_license_fee": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-07",
      "rows": [
        {
          "cells": {
            "base_tax_locator.annual_report_license_fee": {
              "cell_citation_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
              "cell_locator": "WY.llc.base_tax_locator.annual_report_license_fee",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.annual_report_license_fee",
              "value": "The license fee's base and rate are set in W.S. 17-29-209(a); W.S. 17-29-210(a)(iii) provides for the annual fee accompanying the annual report."
            },
            "does_not_reach.annual_report_license_fee": {
              "cell_citation_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
              "cell_locator": "WY.llc.does_not_reach.annual_report_license_fee",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.annual_report_license_fee",
              "value": "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."
            },
            "effective_period.annual_report_license_fee": {
              "cell_citation_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
              "cell_locator": "WY.llc.effective_period.annual_report_license_fee",
              "publish_status": "publish_ready",
              "source_field": "effective_period.annual_report_license_fee",
              "value": "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."
            },
            "filing_rule.annual_report_license_fee": {
              "cell_citation_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
              "cell_locator": "WY.llc.filing_rule.annual_report_license_fee",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.annual_report_license_fee",
              "value": "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."
            },
            "tax_regime.annual_report_license_fee": {
              "cell_citation_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
              "cell_locator": "WY.llc.tax_regime.annual_report_license_fee",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.annual_report_license_fee",
              "value": "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."
            },
            "treatment.annual_report_license_fee": {
              "cell_citation_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
              "cell_locator": "WY.llc.treatment.annual_report_license_fee",
              "publish_status": "publish_ready",
              "source_field": "treatment.annual_report_license_fee",
              "value": "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."
            }
          },
          "jurisdiction": "WY",
          "last_checked": "2026-10-02",
          "official_source_url": "https://wyoleg.gov/statutes/compress/title17.pdf",
          "state": "Wyoming"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-08": {
      "field_definitions": {
        "base_tax_locator.business_and_occupation_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.business_and_occupation_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.business_and_occupation_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.business_and_occupation_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.business_and_occupation_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.business_and_occupation_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-08",
      "rows": [
        {
          "cells": {
            "base_tax_locator.business_and_occupation_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
              "cell_locator": "WA.llc.base_tax_locator.business_and_occupation_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.business_and_occupation_tax",
              "value": "Rate sections: RCW 82.04.290(2)(a), service and other activities, the classification the 2025 legislative finding names for nondeductible investment income, and RCW 82.04.2907(1) for royalties."
            },
            "does_not_reach.business_and_occupation_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
              "cell_locator": "WA.llc.does_not_reach.business_and_occupation_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.business_and_occupation_tax",
              "value": "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."
            },
            "effective_period.business_and_occupation_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.32.875",
              "cell_locator": "WA.llc.effective_period.business_and_occupation_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.business_and_occupation_tax",
              "value": "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."
            },
            "filing_rule.business_and_occupation_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.32.045",
              "cell_locator": "WA.llc.filing_rule.business_and_occupation_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.business_and_occupation_tax",
              "value": "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)."
            },
            "tax_regime.business_and_occupation_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
              "cell_locator": "WA.llc.tax_regime.business_and_occupation_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.business_and_occupation_tax",
              "value": "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."
            },
            "treatment.business_and_occupation_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
              "cell_locator": "WA.llc.treatment.business_and_occupation_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.business_and_occupation_tax",
              "value": "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."
            }
          },
          "jurisdiction": "WA",
          "last_checked": "2026-10-02",
          "official_source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82.04&full=true",
          "state": "Washington"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-09": {
      "field_definitions": {
        "base_tax_locator.business_corporation_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.business_corporation_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.business_corporation_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.business_corporation_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.business_corporation_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.business_corporation_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-09",
      "rows": [
        {
          "cells": {
            "base_tax_locator.business_corporation_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.htm",
              "cell_locator": "RI.llc.base_tax_locator.business_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.business_corporation_tax",
              "value": "The business-corporation tax bases and minimum are located in §44-11-2(a), (c), and (e); no amount is transcribed here."
            },
            "does_not_reach.business_corporation_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.htm",
              "cell_locator": "RI.llc.does_not_reach.business_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.business_corporation_tax",
              "value": "The 90%-receipts adjustment excludes broker, underwriter, and distributor activity; the separate intangible-investment exception is worded only for qualifying corporations."
            },
            "effective_period.business_corporation_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.htm",
              "cell_locator": "RI.llc.effective_period.business_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.business_corporation_tax",
              "value": "The current net-income rate clause applies for tax years beginning on or after January 1, 2015 (§44-11-2(a))."
            },
            "filing_rule.business_corporation_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
              "cell_locator": "RI.llc.filing_rule.business_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.business_corporation_tax",
              "value": "The LLC return is due when its federal return is due, without regard to extension (§7-16-67(b))."
            },
            "tax_regime.business_corporation_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
              "cell_locator": "RI.llc.tax_regime.business_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.business_corporation_tax",
              "value": "A federally corporate LLC pays the chapter 44 business corporation tax; §44-11-2(a) imposes tax on corporate net income."
            },
            "treatment.business_corporation_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.htm",
              "cell_locator": "RI.llc.treatment.business_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.business_corporation_tax",
              "value": "Section 44-11-2 changes the computation for a qualifying securities holder and named investment vehicles, while subsection (e) retains a minimum tax."
            }
          },
          "jurisdiction": "RI",
          "last_checked": "2026-10-02",
          "official_source_url": "https://webserver.rilegislature.gov/Statutes/TITLE7/7-16/7-16-67.htm",
          "state": "Rhode Island"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-10": {
      "field_definitions": {
        "base_tax_locator.business_enterprise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.business_enterprise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.business_enterprise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.business_enterprise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.business_enterprise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.business_enterprise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-10",
      "rows": [
        {
          "cells": {
            "base_tax_locator.business_enterprise_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
              "cell_locator": "NH.llc.base_tax_locator.business_enterprise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.business_enterprise_tax",
              "value": "The Business Enterprise Tax rate and base are set by RSA 77-E:2 and RSA 77-E:1, IX and XV; no amount is given here."
            },
            "does_not_reach.business_enterprise_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
              "cell_locator": "NH.llc.does_not_reach.business_enterprise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.business_enterprise_tax",
              "value": "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."
            },
            "effective_period.business_enterprise_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
              "cell_locator": "NH.llc.effective_period.business_enterprise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.business_enterprise_tax",
              "value": "The current 0.55 percent BET rate applies to taxable periods ending on or after December 31, 2022; no sunset date is stated."
            },
            "filing_rule.business_enterprise_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
              "cell_locator": "NH.llc.filing_rule.business_enterprise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.business_enterprise_tax",
              "value": "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."
            },
            "tax_regime.business_enterprise_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
              "cell_locator": "NH.llc.tax_regime.business_enterprise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.business_enterprise_tax",
              "value": "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."
            },
            "treatment.business_enterprise_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
              "cell_locator": "NH.llc.treatment.business_enterprise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.business_enterprise_tax",
              "value": "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."
            }
          },
          "jurisdiction": "NH",
          "last_checked": "2026-10-02",
          "official_source_url": "https://gc.nh.gov/rsa/html/V/77-E/77-E-mrg.htm",
          "state": "New Hampshire"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-11": {
      "field_definitions": {
        "base_tax_locator.business_privilege_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.business_privilege_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.business_privilege_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.business_privilege_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.business_privilege_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.business_privilege_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-11",
      "rows": [
        {
          "cells": {
            "base_tax_locator.business_privilege_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.base_tax_locator.business_privilege_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.business_privilege_tax",
              "value": "The Business Privilege Tax rate, minimum, and maximum provisions are located in Ala. Code § 40-14A-22(b)-(d)."
            },
            "does_not_reach.business_privilege_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.does_not_reach.business_privilege_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.business_privilege_tax",
              "value": "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."
            },
            "effective_period.business_privilege_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.effective_period.business_privilege_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.business_privilege_tax",
              "value": "The current rate provision applies to taxable years beginning after December 31, 1999."
            },
            "filing_rule.business_privilege_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.filing_rule.business_privilege_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.business_privilege_tax",
              "value": "Every taxpayer files a privilege-tax return for each taxable year in which it is subject to the tax."
            },
            "tax_regime.business_privilege_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.tax_regime.business_privilege_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.business_privilege_tax",
              "value": "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."
            },
            "treatment.business_privilege_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.treatment.business_privilege_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.business_privilege_tax",
              "value": "A qualifying electing family limited liability entity remains subject to Business Privilege Tax but receives a separate statutory maximum-tax treatment."
            }
          },
          "jurisdiction": "AL",
          "last_checked": "2026-10-03",
          "official_source_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-14A-%25%22%7D%7D%2Climit%3A100%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
          "state": "Alabama"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-12": {
      "field_definitions": {
        "base_tax_locator.business_profits_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.business_profits_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.business_profits_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.business_profits_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.business_profits_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.business_profits_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-12",
      "rows": [
        {
          "cells": {
            "base_tax_locator.business_profits_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
              "cell_locator": "NH.llc.base_tax_locator.business_profits_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.business_profits_tax",
              "value": "The Business Profits Tax rate and base are set by RSA 77-A:2 and RSA 77-A:1, III-IV; no amount is given here."
            },
            "does_not_reach.business_profits_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
              "cell_locator": "NH.llc.does_not_reach.business_profits_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.business_profits_tax",
              "value": "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."
            },
            "effective_period.business_profits_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
              "cell_locator": "NH.llc.effective_period.business_profits_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.business_profits_tax",
              "value": "The current 7.5 percent BPT rate applies to taxable periods ending on or after December 31, 2023; no sunset date is stated."
            },
            "filing_rule.business_profits_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
              "cell_locator": "NH.llc.filing_rule.business_profits_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.business_profits_tax",
              "value": "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."
            },
            "tax_regime.business_profits_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
              "cell_locator": "NH.llc.tax_regime.business_profits_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.business_profits_tax",
              "value": "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."
            },
            "treatment.business_profits_tax": {
              "cell_citation_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
              "cell_locator": "NH.llc.treatment.business_profits_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.business_profits_tax",
              "value": "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."
            }
          },
          "jurisdiction": "NH",
          "last_checked": "2026-10-02",
          "official_source_url": "https://gc.nh.gov/rsa/html/V/77-A/77-A-mrg.htm",
          "state": "New Hampshire"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-13": {
      "field_definitions": {
        "base_tax_locator.business_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.business_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.business_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.business_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.business_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.business_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-13",
      "rows": [
        {
          "cells": {
            "base_tax_locator.business_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
              "cell_locator": "TN.llc.base_tax_locator.business_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.business_tax",
              "value": "Base and rates: gross sales per location at classification rates under Tenn. Code Ann. §§ 67-4-708 and 67-4-709; amounts are not reproduced here."
            },
            "does_not_reach.business_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
              "cell_locator": "TN.llc.does_not_reach.business_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.business_tax",
              "value": "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."
            },
            "effective_period.business_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
              "cell_locator": "TN.llc.effective_period.business_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.business_tax",
              "value": "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)."
            },
            "filing_rule.business_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
              "cell_locator": "TN.llc.filing_rule.business_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.business_tax",
              "value": "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."
            },
            "tax_regime.business_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
              "cell_locator": "TN.llc.tax_regime.business_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.business_tax",
              "value": "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."
            },
            "treatment.business_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
              "cell_locator": "TN.llc.treatment.business_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.business_tax",
              "value": "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."
            }
          },
          "jurisdiction": "TN",
          "last_checked": "2026-10-02",
          "official_source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/business-tax.pdf",
          "state": "Tennessee"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-14": {
      "field_definitions": {
        "base_tax_locator.commerce_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.commerce_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.commerce_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.commerce_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.commerce_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.commerce_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-14",
      "rows": [
        {
          "cells": {
            "base_tax_locator.commerce_tax": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
              "cell_locator": "NV.llc.base_tax_locator.commerce_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.commerce_tax",
              "value": "The tax is computed under NRS 363C.300 at the rate for the entity's business category (NRS 363C.310-363C.560, including NRS 363C.470 for management of companies and enterprises)."
            },
            "does_not_reach.commerce_tax": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
              "cell_locator": "NV.llc.does_not_reach.commerce_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.commerce_tax",
              "value": "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."
            },
            "effective_period.commerce_tax": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
              "cell_locator": "NV.llc.effective_period.commerce_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.commerce_tax",
              "value": "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."
            },
            "filing_rule.commerce_tax": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
              "cell_locator": "NV.llc.filing_rule.commerce_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.commerce_tax",
              "value": "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."
            },
            "tax_regime.commerce_tax": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
              "cell_locator": "NV.llc.tax_regime.commerce_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.commerce_tax",
              "value": "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."
            },
            "treatment.commerce_tax": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
              "cell_locator": "NV.llc.treatment.commerce_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.commerce_tax",
              "value": "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."
            }
          },
          "jurisdiction": "NV",
          "last_checked": "2026-10-02",
          "official_source_url": "https://www.leg.state.nv.us/NRS/NRS-363C.html",
          "state": "Nevada"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-15": {
      "field_definitions": {
        "base_tax_locator.commercial_activity_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.commercial_activity_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.commercial_activity_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.commercial_activity_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.commercial_activity_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.commercial_activity_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-15",
      "rows": [
        {
          "cells": {
            "base_tax_locator.commercial_activity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.03",
              "cell_locator": "OH.llc.base_tax_locator.commercial_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.commercial_activity_tax",
              "value": "The CAT rate and exclusion-amount computation are set in R.C. 5751.03; the levy itself is R.C. 5751.02."
            },
            "does_not_reach.commercial_activity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.01",
              "cell_locator": "OH.llc.does_not_reach.commercial_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.commercial_activity_tax",
              "value": "No stated limit on the gross-receipts exclusions themselves was located in R.C. 5751.01(F)(1)-(2)."
            },
            "effective_period.commercial_activity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.02",
              "cell_locator": "OH.llc.effective_period.commercial_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.commercial_activity_tax",
              "value": "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."
            },
            "filing_rule.commercial_activity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.01",
              "cell_locator": "OH.llc.filing_rule.commercial_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.commercial_activity_tax",
              "value": "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."
            },
            "tax_regime.commercial_activity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.02",
              "cell_locator": "OH.llc.tax_regime.commercial_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.commercial_activity_tax",
              "value": "Ohio levies a commercial activity tax on each person with taxable gross receipts for the privilege of doing business in Ohio."
            },
            "treatment.commercial_activity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.01",
              "cell_locator": "OH.llc.treatment.commercial_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.commercial_activity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "OH",
          "last_checked": "2026-10-02",
          "official_source_url": "https://codes.ohio.gov/ohio-revised-code/section-5751.02",
          "state": "Ohio"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-16": {
      "field_definitions": {
        "base_tax_locator.corporate_activity_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporate_activity_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporate_activity_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_activity_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_activity_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_activity_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-16",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporate_activity_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317A.html",
              "cell_locator": "OR.llc.base_tax_locator.corporate_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_activity_tax",
              "value": "The CAT imposition, rate locator and commercial-activity base are in ORS 317A.116, 317A.125 and 317A.100(1)."
            },
            "does_not_reach.corporate_activity_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317A.html",
              "cell_locator": "OR.llc.does_not_reach.corporate_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_activity_tax",
              "value": "The quoted interest, asset-disposition, dividend and pass-through-distribution receipts do not enter commercial activity, subject to the two stated interest exceptions."
            },
            "effective_period.corporate_activity_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/lawsstatutes/2019orLaw0122.pdf",
              "cell_locator": "OR.llc.effective_period.corporate_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_activity_tax",
              "value": "The Corporate Activity Tax provisions apply to tax years beginning on or after January 1, 2020."
            },
            "filing_rule.corporate_activity_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317A.html",
              "cell_locator": "OR.llc.filing_rule.corporate_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_activity_tax",
              "value": "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."
            },
            "tax_regime.corporate_activity_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317A.html",
              "cell_locator": "OR.llc.tax_regime.corporate_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_activity_tax",
              "value": "Oregon imposes an annual Corporate Activity Tax on each person with taxable commercial activity and substantial Oregon nexus."
            },
            "treatment.corporate_activity_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317A.html",
              "cell_locator": "OR.llc.treatment.corporate_activity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_activity_tax",
              "value": "CAT applies to taxable commercial activity, while the quoted holding receipts are excluded and the quoted interest exceptions remain outside that exclusion."
            }
          },
          "jurisdiction": "OR",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317A.html",
          "state": "Oregon"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-17": {
      "field_definitions": {
        "base_tax_locator.corporate_adjusted_gross_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporate_adjusted_gross_income_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporate_adjusted_gross_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_adjusted_gross_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_adjusted_gross_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_adjusted_gross_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-17",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporate_adjusted_gross_income_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.base_tax_locator.corporate_adjusted_gross_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_adjusted_gross_income_tax",
              "value": "The corporate adjusted-gross-income base, rate, and foreign-source-dividend deduction are located in the cited sections."
            },
            "does_not_reach.corporate_adjusted_gross_income_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.does_not_reach.corporate_adjusted_gross_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_adjusted_gross_income_tax",
              "value": "The deduction is confined by definition to dividends from a foreign corporation."
            },
            "effective_period.corporate_adjusted_gross_income_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.effective_period.corporate_adjusted_gross_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_adjusted_gross_income_tax",
              "value": "The current corporate adjusted gross income tax rate applies after June 30, 2021."
            },
            "filing_rule.corporate_adjusted_gross_income_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.filing_rule.corporate_adjusted_gross_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_adjusted_gross_income_tax",
              "value": "Every corporation with Indiana-source gross income files a return; the statute states the applicable fourth- or fifth-month due-date rule."
            },
            "tax_regime.corporate_adjusted_gross_income_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.tax_regime.corporate_adjusted_gross_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_adjusted_gross_income_tax",
              "value": "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."
            },
            "treatment.corporate_adjusted_gross_income_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.treatment.corporate_adjusted_gross_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_adjusted_gross_income_tax",
              "value": "A corporation-classified LLC remains within corporate adjusted gross income tax, while qualifying foreign-source dividends receive the ownership-tiered statutory deduction."
            }
          },
          "jurisdiction": "IN",
          "last_checked": "2026-10-03",
          "official_source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
          "state": "Indiana"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-18": {
      "field_definitions": {
        "base_tax_locator.corporate_excise": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporate_excise": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporate_excise": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_excise": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_excise": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_excise": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-18",
      "rows": [
        {
          "cells": {
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              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section39",
              "cell_locator": "MA.llc.base_tax_locator.corporate_excise",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_excise",
              "value": "The corporate excise base, measures, and minimum are located in Chapter 63 §§ 30 and 39."
            },
            "does_not_reach.corporate_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
              "cell_locator": "MA.llc.does_not_reach.corporate_excise",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_excise",
              "value": "The general § 39 excise does not reach a corporation that is taxable under the separate § 38B security-corporation excise."
            },
            "effective_period.corporate_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section39",
              "cell_locator": "MA.llc.effective_period.corporate_excise",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_excise",
              "value": "Section 39 states the current income-measure period as tax years beginning on or after January 1, 2012."
            },
            "filing_rule.corporate_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter62C/Section11",
              "cell_locator": "MA.llc.filing_rule.corporate_excise",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_excise",
              "value": "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."
            },
            "tax_regime.corporate_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section39",
              "cell_locator": "MA.llc.tax_regime.corporate_excise",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_excise",
              "value": "Section 39 imposes the corporate excise on every covered business corporation for stated charter, business, and property incidents in Massachusetts."
            },
            "treatment.corporate_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
              "cell_locator": "MA.llc.treatment.corporate_excise",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_excise",
              "value": "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."
            }
          },
          "jurisdiction": "MA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section39",
          "state": "Massachusetts"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-19": {
      "field_definitions": {
        "base_tax_locator.corporate_franchise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporate_franchise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporate_franchise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_franchise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_franchise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_franchise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-06",
      "matrix_id": "pp-holding-entity-tax:state-tax-19",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporate_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.base_tax_locator.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_franchise_tax",
              "value": "The corporate tax rate and minimum-tax provisions are located at D.C. Code § 47-1807.02(a)-(b)."
            },
            "does_not_reach.corporate_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.does_not_reach.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_franchise_tax",
              "value": "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."
            },
            "effective_period.corporate_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.effective_period.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_franchise_tax",
              "value": "The current corporate levy provision applies for taxable years beginning after December 31, 2017."
            },
            "filing_rule.corporate_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.filing_rule.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_franchise_tax",
              "value": "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."
            },
            "tax_regime.corporate_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.tax_regime.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_franchise_tax",
              "value": "The corporate franchise tax applies to every domestic or foreign corporation for current taxable years."
            },
            "treatment.corporate_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.treatment.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_franchise_tax",
              "value": "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."
            }
          },
          "jurisdiction": "DC",
          "last_checked": "2026-10-03",
          "official_source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
          "state": "District of Columbia"
        },
        {
          "cells": {
            "base_tax_locator.corporate_franchise_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025A/",
              "cell_locator": "ID.llc.base_tax_locator.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_franchise_tax",
              "value": "The base and rate for the franchise tax are located in Idaho Code § 63-3025A; no amount is transcribed here."
            },
            "does_not_reach.corporate_franchise_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3027/",
              "cell_locator": "ID.llc.does_not_reach.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_franchise_tax",
              "value": "The stated interest/dividend allocation reaches Idaho-commercial-domicile income unless it is apportionable; the rule does not state a general holding-entity exemption."
            },
            "effective_period.corporate_franchise_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025A/",
              "cell_locator": "ID.llc.effective_period.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_franchise_tax",
              "value": "The cited operative period for the franchise tax begins on 2001-01-01."
            },
            "filing_rule.corporate_franchise_tax": {
              "cell_citation_url": "https://tax.idaho.gov/taxes/income-tax/business-income/guides-for-certain-businesses/income-tax-for-corporations/",
              "cell_locator": "ID.llc.filing_rule.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_franchise_tax",
              "value": "The corporate Idaho return is due on the fifteenth day of the fourth month after the tax year closes."
            },
            "tax_regime.corporate_franchise_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025A/",
              "cell_locator": "ID.llc.tax_regime.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_franchise_tax",
              "value": "Idaho imposes the franchise tax on the corporate branch described in Idaho Code § 63-3025A."
            },
            "treatment.corporate_franchise_tax": {
              "cell_citation_url": "https://tax.idaho.gov/taxes/income-tax/business-income/guides-for-certain-businesses/income-tax-for-corporations/",
              "cell_locator": "ID.llc.treatment.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_franchise_tax",
              "value": "Tax Commission guidance lists an inactive or name-holder corporation among corporations that must file; it states no holding-only carve-out."
            }
          },
          "jurisdiction": "ID",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025A/",
          "state": "Idaho"
        },
        {
          "cells": {
            "base_tax_locator.corporate_franchise_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.base_tax_locator.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_franchise_tax",
              "value": "The franchise-tax measures and rate are located in §§290.02 and 290.06, subd. 1; §290.0921 supplies the included AMT component. No amount is transcribed here."
            },
            "does_not_reach.corporate_franchise_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.does_not_reach.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_franchise_tax",
              "value": "The dividend deduction does not reach dividends from a federally exempt corporation or a REIT and is subject to the holding-business exclusion."
            },
            "effective_period.corporate_franchise_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.effective_period.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_franchise_tax",
              "value": "No current sunset or effective period for the franchise-tax regime was stated in the complete chapter 290 capture."
            },
            "filing_rule.corporate_franchise_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.filing_rule.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_franchise_tax",
              "value": "A corporation within Minnesota's jurisdiction to tax must file a return."
            },
            "tax_regime.corporate_franchise_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.tax_regime.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_franchise_tax",
              "value": "Minnesota imposes an annual franchise tax on a corporation whose state contacts produce Minnesota-source gross income."
            },
            "treatment.corporate_franchise_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.treatment.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_franchise_tax",
              "value": "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."
            }
          },
          "jurisdiction": "MN",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
          "state": "Minnesota"
        },
        {
          "cells": {
            "base_tax_locator.corporate_franchise_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
              "cell_locator": "MS.llc.base_tax_locator.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_franchise_tax",
              "value": "The domestic and foreign franchise-tax bases are located in §§27-13-5 and 27-13-7; no amount is transcribed here."
            },
            "does_not_reach.corporate_franchise_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20CIT%20INSTRUCTIONS%2083-100%20-%20Final%20%2001.14.2026.pdf",
              "cell_locator": "MS.llc.does_not_reach.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_franchise_tax",
              "value": "The holding-company exclusion is limited to the calculated portion of capital attributable to stock or securities of a subsidiary corporation."
            },
            "effective_period.corporate_franchise_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
              "cell_locator": "MS.llc.effective_period.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_franchise_tax",
              "value": "The corporation franchise tax law is repealed from and after January 1, 2028."
            },
            "filing_rule.corporate_franchise_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions",
              "cell_locator": "MS.llc.filing_rule.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_franchise_tax",
              "value": "The corporate income and franchise tax return is due on the fifteenth day of the fourth month after the taxable year closes."
            },
            "tax_regime.corporate_franchise_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
              "cell_locator": "MS.llc.tax_regime.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_franchise_tax",
              "value": "Mississippi imposes a franchise or excise tax on domestic and foreign corporations and partnerships treated as corporations."
            },
            "treatment.corporate_franchise_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/sites/default/files/tax-forms/business/2025%20CIT%20INSTRUCTIONS%2083-100%20-%20Final%20%2001.14.2026.pdf",
              "cell_locator": "MS.llc.treatment.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_franchise_tax",
              "value": "A qualifying holding corporation computes an exclusion from capital for the stated portion of its investment in subsidiary stock or securities."
            }
          },
          "jurisdiction": "MS",
          "last_checked": "2026-10-06",
          "official_source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
          "state": "Mississippi"
        },
        {
          "cells": {
            "base_tax_locator.corporate_franchise_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/210",
              "cell_locator": "NY.llc.base_tax_locator.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_franchise_tax",
              "value": "The Article 9-A computation bases are located in N.Y. Tax Law §210(1)."
            },
            "does_not_reach.corporate_franchise_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/208",
              "cell_locator": "NY.llc.does_not_reach.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_franchise_tax",
              "value": "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."
            },
            "effective_period.corporate_franchise_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/210",
              "cell_locator": "NY.llc.effective_period.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_franchise_tax",
              "value": "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."
            },
            "filing_rule.corporate_franchise_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/211",
              "cell_locator": "NY.llc.filing_rule.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_franchise_tax",
              "value": "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."
            },
            "tax_regime.corporate_franchise_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/209",
              "cell_locator": "NY.llc.tax_regime.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_franchise_tax",
              "value": "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)."
            },
            "treatment.corporate_franchise_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/208",
              "cell_locator": "NY.llc.treatment.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_franchise_tax",
              "value": "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."
            }
          },
          "jurisdiction": "NY",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.nysenate.gov/legislation/laws/TAX/209",
          "state": "New York"
        },
        {
          "cells": {
            "base_tax_locator.corporate_franchise_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.base_tax_locator.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_franchise_tax",
              "value": "The base, rate, and minimum-tax mechanism for utah corporation franchise tax are located at Utah Code § 59-7-104; no amount is transcribed here."
            },
            "does_not_reach.corporate_franchise_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.does_not_reach.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_franchise_tax",
              "value": "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."
            },
            "effective_period.corporate_franchise_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.effective_period.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_franchise_tax",
              "value": "The current imposition section is identified in the official Code XML as amended in the 2026 General Session."
            },
            "filing_rule.corporate_franchise_tax": {
              "cell_citation_url": "https://tax.utah.gov/business/corporate-income-tax/c-corp-tax/",
              "cell_locator": "UT.llc.filing_rule.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_franchise_tax",
              "value": "A C corporation files Utah Form TC-20 for the corporation franchise or income tax."
            },
            "tax_regime.corporate_franchise_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.tax_regime.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_franchise_tax",
              "value": "Utah imposes an annual tax on a nonexempt domestic or foreign corporation for exercising its corporate franchise or doing business in Utah."
            },
            "treatment.corporate_franchise_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.treatment.corporate_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_franchise_tax",
              "value": "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."
            }
          },
          "jurisdiction": "UT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
          "state": "Utah"
        }
      ],
      "scope_label": "6 jurisdictions"
    },
    "state-tax-20": {
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        "effective_period.corporate_income_franchise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_income_franchise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_income_franchise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_income_franchise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-20",
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              "cell_locator": "FL.llc.base_tax_locator.corporate_income_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_franchise_tax",
              "value": "The imposition, net-income base, adjusted-federal-income rules, and exemption are located at Florida Statutes §§ 220.11 through 220.14."
            },
            "does_not_reach.corporate_income_franchise_tax": {
              "cell_citation_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
              "cell_locator": "FL.llc.does_not_reach.corporate_income_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_franchise_tax",
              "value": "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."
            },
            "effective_period.corporate_income_franchise_tax": {
              "cell_citation_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
              "cell_locator": "FL.llc.effective_period.corporate_income_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_franchise_tax",
              "value": "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."
            },
            "filing_rule.corporate_income_franchise_tax": {
              "cell_citation_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
              "cell_locator": "FL.llc.filing_rule.corporate_income_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_franchise_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_franchise_tax": {
              "cell_citation_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
              "cell_locator": "FL.llc.tax_regime.corporate_income_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_franchise_tax",
              "value": "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."
            },
            "treatment.corporate_income_franchise_tax": {
              "cell_citation_url": "https://www.flsenate.gov/Laws/Statutes/2025/Chapter220/All",
              "cell_locator": "FL.llc.treatment.corporate_income_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_franchise_tax",
              "value": "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."
            }
          },
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          "last_checked": "2026-10-03",
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        }
      ],
      "scope_label": "1 jurisdictions"
    },
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      "field_definitions": {
        "base_tax_locator.corporate_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
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        "effective_period.corporate_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
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        {
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              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate-income tax rate is located in Ala. Code § 40-18-31(a), and the taxable-income base is located in § 40-18-33."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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)."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The complete corporate-income provisions state no effective or sunset period for the current levy or the dividend deduction."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "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."
            },
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              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "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."
            }
          },
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          "official_source_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
          "state": "Alabama"
        },
        {
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              "cell_citation_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2024S2%2FPublic%2FACT4.pdf",
              "cell_locator": "AR.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The domestic corporate-income-tax rate schedule is located at Ark. Code Ann. § 26-51-205(a)(5), as amended by Act 4 of 2024, § 2."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/CorporationIncomeTaxInstructions_2025.pdf",
              "cell_locator": "AR.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The exemption is limited to qualifying dividends; the instructions separately require taxable interest, gross rents, and gross royalties to be entered."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2024S2%2FPublic%2FACT4.pdf",
              "cell_locator": "AR.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current domestic-corporation provision applies to tax years beginning on or after January 1, 2024."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/CorporationIncomeTaxInstructions_2025.pdf",
              "cell_locator": "AR.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "Arkansas corporate income-tax returns are due on the fifteenth day of the fourth month following the end of the tax year."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2024S2%2FPublic%2FACT4.pdf",
              "cell_locator": "AR.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "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."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/CorporationIncomeTaxInstructions_2025.pdf",
              "cell_locator": "AR.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "A corporation-classified LLC remains in the corporate-income-tax regime, but dividends from an 80%-or-greater directly owned subsidiary are exempt."
            }
          },
          "jurisdiction": "AR",
          "last_checked": "2026-10-03",
          "official_source_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2024S2%2FPublic%2FACT4.pdf",
          "state": "Arkansas"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01111.htm",
              "cell_locator": "AZ.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate tax base and rate are located at A.R.S. § 43-1111."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01122.htm",
              "cell_locator": "AZ.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The domestic-corporation dividend subtraction uses a 50%-or-more voting-control threshold."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01111.htm",
              "cell_locator": "AZ.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "A.R.S. § 43-1111 states the current rate for taxable years beginning after December 31, 2016."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/00307.htm",
              "cell_locator": "AZ.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "A corporation subject to Title 43 must file an Arizona return even when it has no federal taxable income."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01111.htm",
              "cell_locator": "AZ.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Arizona imposes corporate income tax on the entire Arizona taxable income of every corporation, subject to stated exemptions."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01122.htm",
              "cell_locator": "AZ.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Controlled-corporation dividends are subtracted when computing Arizona corporate taxable income."
            }
          },
          "jurisdiction": "AZ",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.azleg.gov/ars/43/01111.htm",
          "state": "Arizona"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate income-tax base and rate schedule are located in §39-22-301(1)(d)(I)."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "No special statutory limit for holding or passive entities was located in the complete C-corporation income-tax subpart."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current statutory rate provision applies to income-tax years commencing on or after January 1, 2022, subject to §39-22-627."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "Every C corporation subject to the article must file a return reporting federal taxable income, Colorado modifications and credits, and required information."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Colorado imposes an annual income tax on each domestic or foreign C corporation and combined group doing business in Colorado."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "The generally applicable corporate income tax applies; no holding-entity carve-out was located in the complete C-corporation subpart."
            }
          },
          "jurisdiction": "CO",
          "last_checked": "2026-10-03",
          "official_source_url": "https://olls.info/crs/crs2026-title-39.pdf",
          "state": "Colorado"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://rules.sos.ga.gov/gac/560-7-3",
              "cell_locator": "GA.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate-income-tax base is located at O.C.G.A. § 48-7-21 and Rule 560-7-3-.06(1)."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://rules.sos.ga.gov/gac/560-7-3",
              "cell_locator": "GA.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The cited dividend rule defines an affiliated corporation by IRC § 1504 group membership; it does not state a general deduction for every investment holding."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://rules.sos.ga.gov/gac/560-7-3",
              "cell_locator": "GA.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "No effective or sunset period for the current corporate-income-tax regime or affiliated-corporation dividend rule was stated in the searched official materials."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://dor.georgia.gov/document/document/2025-it611-corporate-income-tax-instruction-booklet/download",
              "cell_locator": "GA.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "A corporation with Georgia property, business, or source income must file a Georgia income-tax return."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://dor.georgia.gov/taxes/taxes-corporations",
              "cell_locator": "GA.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Georgia imposes a corporate income tax on corporations."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://advance.lexis.com/documentpage/?config=00JAA1MDBlYzczZi1lYjFlLTQxMTgtYWE3OS02YTgyOGM2NWJlMDYKAFBvZENhdGFsb2feed0oM9qoQOMCSJFX5qkd&pddocfullpath=%2Fshared%2Fdocument%2Fstatutes-legislation%2Furn%3AcontentItem%3A6JK8-FWH3-S5BN-P2SK-00008-00&pdcontentcomponentid=234186",
              "cell_locator": "GA.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Qualifying affiliate dividends are subtracted from taxable income, reduced by expenses directly attributable to the dividend income."
            }
          },
          "jurisdiction": "GA",
          "last_checked": "2026-10-05",
          "official_source_url": "https://dor.georgia.gov/taxes/taxes-corporations",
          "state": "Georgia"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate taxable-income base and rates are located in §235-71(a), with scope in §235-4(d) and dividend modifications in §235-7(c); no amount is transcribed here."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The dividend rules remove the stated deductible portions from Hawaii taxable income; they do not state a general exemption for a holding LLC."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "No current effective or sunset period for the corporate levy or dividend modification was stated in the complete chapter 235 capture."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Hawaii imposes tax on the taxable income of every corporation, including a corporation carrying on business in partnership."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Corporate dividend income receives Hawaii-specific deduction treatment: full deductions for three stated classes and a 70% deduction for qualifying other-corporation dividends."
            }
          },
          "jurisdiction": "HI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
          "state": "Hawaii"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate income-tax base and rate mechanism are located at Iowa Code § 422.33(1); no amount is transcribed here."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://revenue.iowa.gov/taxes/tax-guidance/business-income-tax/iowa-corporate-income-tax-rates",
              "cell_locator": "IA.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The Department identifies the current corporate-rate schedule as effective for tax years beginning on or after January 1, 2024."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Iowa imposes corporate income tax on each corporation doing business in Iowa or deriving income from Iowa sources."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "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."
            }
          },
          "jurisdiction": "IA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
          "state": "Iowa"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025/",
              "cell_locator": "ID.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The base and rate for the tax on corporate income are located in Idaho Code § 63-3025; no amount is transcribed here."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3027/",
              "cell_locator": "ID.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The stated interest/dividend allocation reaches Idaho-commercial-domicile income unless it is apportionable; the rule does not state a general holding-entity exemption."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025/",
              "cell_locator": "ID.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The cited operative period for the tax on corporate income begins on 2025-01-01."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://tax.idaho.gov/taxes/income-tax/business-income/guides-for-certain-businesses/income-tax-for-corporations/",
              "cell_locator": "ID.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "The corporate Idaho return is due on the fifteenth day of the fourth month after the tax year closes."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025/",
              "cell_locator": "ID.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Idaho imposes the tax on corporate income on the corporate branch described in Idaho Code § 63-3025."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://tax.idaho.gov/taxes/income-tax/business-income/guides-for-certain-businesses/income-tax-for-corporations/",
              "cell_locator": "ID.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Tax Commission guidance lists an inactive or name-holder corporation among corporations that must file; it states no holding-only carve-out."
            }
          },
          "jurisdiction": "ID",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3025/",
          "state": "Idaho"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate net-income imposition is located at 35 ILCS 5/201(a), and the current corporate rate at 35 ILCS 5/201(b)(14)."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html",
              "cell_locator": "IL.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The stated current corporate rate applies to taxable years beginning on or after July 1, 2017."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K502.html",
              "cell_locator": "IL.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Illinois imposes a net-income tax on corporations; the current corporate rate provision applies to taxable years beginning on or after July 1, 2017."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html",
              "cell_locator": "IL.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "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."
            }
          },
          "jurisdiction": "IL",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
          "state": "Illinois"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0110b_section/079_032_0110b_k/",
              "cell_locator": "KS.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The Kansas corporate income-tax base and rates are located at K.S.A. 79-32,110b(c)."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0138_section/079_032_0138_k/",
              "cell_locator": "KS.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0138_section/079_032_0138_k/",
              "cell_locator": "KS.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "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)."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.ksrevenue.gov/corpbook25.html",
              "cell_locator": "KS.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0110b_section/079_032_0110b_k/",
              "cell_locator": "KS.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Kansas imposes corporate income tax on every corporation doing business in Kansas or deriving income from Kansas sources."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0138_section/079_032_0138_k/",
              "cell_locator": "KS.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Qualifying foreign-corporation dividends receive an 80% subtraction from federal taxable income in computing Kansas corporate taxable income."
            }
          },
          "jurisdiction": "KS",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0110b_section/079_032_0110b_k/",
          "state": "Kansas"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=101674",
              "cell_locator": "LA.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporation income-tax rate is located in La. R.S. 47:287.12."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=101725",
              "cell_locator": "LA.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The stated holding-income deductions address dividends and interest; the interest provision separately addresses the controlled-corporation election."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=101674",
              "cell_locator": "LA.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current rate provision applies to taxable years beginning on or after January 1, 2025."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=101692",
              "cell_locator": "LA.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "Every corporation subject to the tax must file a return stating gross-income items and allowed deductions and credits."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.la.gov/Legis/Law.aspx?d=101673",
              "cell_locator": "LA.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "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."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=101725",
              "cell_locator": "LA.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Dividends and interest otherwise included in gross income receive statutory deductions, subject to the controlled-corporation interest election stated in the provision."
            }
          },
          "jurisdiction": "LA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.legis.la.gov/Legis/Law.aspx?d=101673",
          "state": "Louisiana"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate rate is located at § 10-105(b), and the corporate Maryland modified-income base is located at § 10-304."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The subtraction is limited to included dividends, at least 50% direct or indirect ownership, and a payer organized under foreign law."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current corporate levy and dividend-subtraction provisions do not state an effective or sunset period in the codified sections."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "An LLC classified under federal Subchapter C or S files the appropriate corporate return; a disregarded single-member LLC reports through its member."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Maryland imposes income tax on the Maryland taxable income of each corporation, subject to the statutory exclusions."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Qualifying foreign-corporation dividends are subtracted from federal taxable income when determining Maryland modified income."
            }
          },
          "jurisdiction": "MD",
          "last_checked": "2026-10-03",
          "official_source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
          "state": "Maryland"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://legislature.maine.gov/statutes/36/title36sec5200.html",
              "cell_locator": "ME.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "Rates and imposition: § 5200(1-A); Maine taxable-income modifications: § 5200-A."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://legislature.maine.gov/statutes/36/title36sec5200-A.html",
              "cell_locator": "ME.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The dividend subtraction excludes subpart F, § 951A and § 965 income; § 5200-B also preserves federal Public Law 86-272 protection."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://legislature.maine.gov/statutes/36/title36sec5200.html",
              "cell_locator": "ME.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current rate schedule applies to tax years beginning on or after January 1, 2018."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://legislature.maine.gov/statutes/36/title36sec5220.html",
              "cell_locator": "ME.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "Every taxable corporation required to file a federal income-tax return files a Maine return; a unitary affiliate also files the statutory combined report."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://legislature.maine.gov/statutes/36/title36sec5200.html",
              "cell_locator": "ME.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "For tax years beginning on or after January 1, 2018, § 5200 imposes tax on each taxable corporation and each qualifying unitary group."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://legislature.maine.gov/statutes/36/title36sec5202-A.html",
              "cell_locator": "ME.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "A corporate SBIC meeting § 5202-A is exempt under Part 8; § 5200-A separately subtracts 50% of specified affiliated-corporation dividend income."
            }
          },
          "jurisdiction": "ME",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.maine.gov/statutes/36/title36sec5200.html",
          "state": "Maine"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The Corporate Income Tax base and holding-income adjustments are located in MCL 206.623; MCL 206.667 addresses alternative apportionment."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The quoted deductions are bounded by their stated sources: specified non-U.S. payors/foreign operating entities and United States obligations."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The Corporate Income Tax part was added by 2011 PA 38, effective January 1, 2012."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "The annual or final corporate-income-tax return is due by the last day of the fourth month after the tax year ends."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "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."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "A corporate-classified holding LLC receives different base treatment for the specified foreign dividends/royalties and U.S.-obligation interest."
            }
          },
          "jurisdiction": "MI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
          "state": "Michigan"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v",
              "cell_locator": "MO.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporation-income base is located at § 143.431.1 and the current rate at § 143.071.3."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v",
              "cell_locator": "MO.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.071",
              "cell_locator": "MO.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current corporation-income provision applies to tax years beginning on or after January 1, 2020."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.481",
              "cell_locator": "MO.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.071",
              "cell_locator": "MO.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "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."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://revisor.mo.gov/main/OneChapter.aspx?chapter=143&idx=v",
              "cell_locator": "MO.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "A corporate-classified holding LLC remains within the regime, while corporate dividends and other holding receipts receive the stated subtraction and source-allocation treatment."
            }
          },
          "jurisdiction": "MO",
          "last_checked": "2026-10-03",
          "official_source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=143.071",
          "state": "Missouri"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
              "cell_locator": "MS.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate income-tax base and rate are located in Miss. Code §27-7-5; no amount is transcribed here."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions",
              "cell_locator": "MS.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The stated allocation procedure is limited to nonbusiness income and wholly passive investment income from outside Mississippi and requires supporting explanation."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
              "cell_locator": "MS.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The cited imposition applies to the listed calendar and fiscal years and ‘all taxable years thereafter.’"
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions",
              "cell_locator": "MS.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "A corporation must file a corporate income and franchise tax return even when inactive; DOR places a federally corporate LLC in this branch."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
              "cell_locator": "MS.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Mississippi imposes income tax on corporate net income; an LLC reaches this filing branch when classified federally as a corporation."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/business/business-tax-frequently-asked-questions",
              "cell_locator": "MS.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "DOR treats the identified passive out-of-state investment income through a separate allocation and documentation procedure, not as an entity exemption."
            }
          },
          "jurisdiction": "MS",
          "last_checked": "2026-10-02",
          "official_source_url": "https://billstatus.ls.state.ms.us/documents/2016/html/SB/2800-2899/SB2858SG.htm",
          "state": "Mississippi"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0210/0150-0310-0010-0210.html",
              "cell_locator": "MT.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate-income levy, income base, deductions, rate, and minimum-tax locators are in the cited sections."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0140/0150-0310-0010-0140.html",
              "cell_locator": "MT.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The RIC deduction excludes dividends attributable to income not taxed when earned and disallows a dividends-received deduction; the NOL deduction is also unavailable."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0010/0150-0310-0010-0010.html",
              "cell_locator": "MT.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The corporate income tax provision states that a corporation engaged in Montana business pays the tax annually."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0110/0150-0310-0010-0110.html",
              "cell_locator": "MT.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "A corporation files an accurate net-income return for each tax period under the stated calendar- or fiscal-year due-date rule."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0010/0150-0310-0010-0010.html",
              "cell_locator": "MT.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "A federally corporation-classified LLC is a corporation under Montana law and pays corporate income tax annually when engaged in business in Montana."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0140/0150-0310-0010-0140.html",
              "cell_locator": "MT.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "A qualifying regulated investment company remains within the corporate regime but receives the stated dividends-paid deduction with express exclusions."
            }
          },
          "jurisdiction": "MT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0310/part_0010/section_0010/0150-0310-0010-0010.html",
          "state": "Montana"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.3.html",
              "cell_locator": "NC.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "Imposition and rate: § 105-130.3; State net-income adjustments: § 105-130.5."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.5.html",
              "cell_locator": "NC.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "Expenses related to untaxed income remain nondeductible; for untaxed dividends, the expense adjustment is capped at 15% of the dividends."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.3.html",
              "cell_locator": "NC.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "Section 105-130.3 lists 2.25% for 2025, 2% for 2026, 1% for 2028, and 0% after 2029."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.17.html",
              "cell_locator": "NC.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "A corporation generally files its return by the fifteenth day of the fourth month after its income year closes."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.3.html",
              "cell_locator": "NC.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "State net income tax applies to every C corporation doing business in North Carolina; the 2026 rate shown is 2%."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.5.html",
              "cell_locator": "NC.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Specified dividend and foreign-income amounts are deducted from federal taxable income, net of related expenses."
            }
          },
          "jurisdiction": "NC",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-130.3.html",
          "state": "North Carolina"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://ndlegis.gov/cencode/t57c38.pdf",
              "cell_locator": "ND.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate income-tax rate brackets and taxable-income base are located at N.D.C.C. § 57-38-30."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://ndlegis.gov/cencode/t57c38.pdf",
              "cell_locator": "ND.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://ndlegis.gov/cencode/t57c38.pdf",
              "cell_locator": "ND.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current corporate levy, LLC-classification, combined-report dividend, and filing provisions do not state an effective or sunset period."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://ndlegis.gov/cencode/t57c38.pdf",
              "cell_locator": "ND.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://ndlegis.gov/cencode/t57c38.pdf",
              "cell_locator": "ND.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "North Dakota imposes an annual tax on the taxable income of every domestic and foreign corporation."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://ndlegis.gov/cencode/t57c38.pdf",
              "cell_locator": "ND.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "In the permitted or required combined computation, dividends from a corporation whose assets are included may not be included in income."
            }
          },
          "jurisdiction": "ND",
          "last_checked": "2026-10-03",
          "official_source_url": "https://ndlegis.gov/cencode/t57c38.pdf",
          "state": "North Dakota"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
              "cell_locator": "NE.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate income-tax base and rate schedule are located at Neb. Rev. Stat. § 77-2734.02(1); no amount is transcribed here."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://revenue.nebraska.gov/about/legal-information/regulations/chapter-24-corporate-income-tax",
              "cell_locator": "NE.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
              "cell_locator": "NE.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current statute states schedules for tax years beginning in 2026 and for tax years beginning on or after January 1, 2027."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
              "cell_locator": "NE.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "Each corporate taxpayer files one Nebraska income-tax return for each taxable year."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
              "cell_locator": "NE.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Nebraska imposes income tax on the taxable income of every corporate taxpayer doing business in the state."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://revenue.nebraska.gov/about/legal-information/regulations/chapter-24-corporate-income-tax",
              "cell_locator": "NE.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "The general rule reaches a corporate-classified entity with Nebraska-source federal taxable income; no general holding/passive carve-out was located."
            }
          },
          "jurisdiction": "NE",
          "last_checked": "2026-10-03",
          "official_source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.02",
          "state": "Nebraska"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate-income-tax rate is located at NMSA 1978, § 7-2A-5."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "The federal-special-deduction base rule does not remove state or local bond interest exempt under the IRC; New Mexico adds that interest back."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The 2026 base-income amendment was effective May 20, 2026 and applies to taxable years beginning on or after January 1, 2027."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "A covered corporation must file the prescribed return and pay by the due date of its federal corporate income-tax return."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Corporate income tax applies to a corporation doing business in New Mexico or deriving income from New Mexico property or employment."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "A corporation-classified LLC remains in the regime, but its New Mexico base begins after the federal special deductions in IRC §§ 241-249."
            }
          },
          "jurisdiction": "NM",
          "last_checked": "2026-10-03",
          "official_source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
          "state": "New Mexico"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate taxable-income definitions, imposition, and Oklahoma adjustments are located at Title 68 §§ 2353, 2355(H), and 2358."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current corporate rate provision applies to taxable years beginning after December 31, 2021."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "Every corporation files an annual return stating taxable income and the Oklahoma adjustments, signed by the specified corporate officer."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Oklahoma imposes corporate income tax on the Oklahoma taxable income of every corporation doing business in the state or deriving income from Oklahoma sources."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Section 2355(H) taxes every corporation meeting its business-or-income scope; the complete-act search located no general holding-company exemption."
            }
          },
          "jurisdiction": "OK",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
          "state": "Oklahoma"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporate income-tax base and rate are located at S.C. Code § 12-6-530."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "An S corporation is outside Chapter 6 tax to the extent it is exempt from federal corporate income tax; shareholder inclusion remains stated separately."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "No effective or sunset period for § 12-6-530 is stated in its history or the complete Chapter 6 search."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "A corporation subject to Chapter 6 files a return; the statute separately states when an S corporation must file."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "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."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "Section 12-6-530 uses universal corporate-classification language; no general holding-entity carve-out was located in Chapter 6."
            }
          },
          "jurisdiction": "SC",
          "last_checked": "2026-10-02",
          "official_source_url": "https://www.scstatehouse.gov/code/t12c006.php",
          "state": "South Carolina"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The base, rate, and minimum-tax mechanism for utah corporation income tax are located at Utah Code § 59-7-201; no amount is transcribed here."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The current imposition section is identified in the official Code XML as amended in the 2026 General Session."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://tax.utah.gov/business/corporate-income-tax/c-corp-tax/",
              "cell_locator": "UT.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "A C corporation files Utah Form TC-20 for the corporation franchise or income tax."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Utah imposes income tax on a nonexempt corporation's Utah-source taxable income for periods not included in its franchise-tax base."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
              "cell_locator": "UT.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "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."
            }
          },
          "jurisdiction": "UT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.xml",
          "state": "Utah"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
              "cell_locator": "VA.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The corporation-income-tax rate and imposition are located at Va. Code § 58.1-400."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
              "cell_locator": "VA.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "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."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
              "cell_locator": "VA.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "Article 10 states no commencement or sunset date for the 50%-ownership dividend subtraction in Va. Code § 58.1-402(C)(10)."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article14/",
              "cell_locator": "VA.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
              "cell_locator": "VA.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Virginia annually imposes corporation income tax on every Virginia corporation and every foreign corporation having income from Virginia sources."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
              "cell_locator": "VA.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "The LLC remains in the corporation-income-tax regime, but qualifying dividends are subtracted from the federal-taxable-income starting point."
            }
          },
          "jurisdiction": "VA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article10/",
          "state": "Virginia"
        },
        {
          "cells": {
            "base_tax_locator.corporate_income_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.base_tax_locator.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_income_tax",
              "value": "The Corporate Income Tax base and rate schedule are located at 32 V.S.A. § 5832."
            },
            "does_not_reach.corporate_income_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.does_not_reach.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_income_tax",
              "value": "Section 5838 states that an electing qualifying digital business entity is not subject to section 5832."
            },
            "effective_period.corporate_income_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.effective_period.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_income_tax",
              "value": "The digital-business-entity election that supplies the different treatment took effect January 1, 2010."
            },
            "filing_rule.corporate_income_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.filing_rule.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_income_tax",
              "value": "Every taxable corporation must file the Vermont corporate income-tax return by the federal-return due date."
            },
            "tax_regime.corporate_income_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.tax_regime.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_income_tax",
              "value": "Corporate Income Tax is imposed on income earned or received by every taxable corporation."
            },
            "treatment.corporate_income_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.treatment.corporate_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_income_tax",
              "value": "A corporation that qualifies and elects as a digital business entity uses the amount determined under the separate Digital Business Entity Franchise Tax provision."
            }
          },
          "jurisdiction": "VT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
          "state": "Vermont"
        }
      ],
      "scope_label": "26 jurisdictions"
    },
    "state-tax-22": {
      "field_definitions": {
        "base_tax_locator.corporate_license_fee": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporate_license_fee": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporate_license_fee": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_license_fee": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_license_fee": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_license_fee": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-22",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporate_license_fee": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c020.php",
              "cell_locator": "SC.llc.base_tax_locator.corporate_license_fee",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_license_fee",
              "value": "The corporate license-fee base, rate, and minimum are located at S.C. Code § 12-20-50(A)."
            },
            "does_not_reach.corporate_license_fee": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c020.php",
              "cell_locator": "SC.llc.does_not_reach.corporate_license_fee",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_license_fee",
              "value": "The holding-company reduction is limited to the attributed parent contribution, qualifying subsidiary expansion, zone, and completion conditions stated in § 12-20-50(C)."
            },
            "effective_period.corporate_license_fee": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c020.php",
              "cell_locator": "SC.llc.effective_period.corporate_license_fee",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_license_fee",
              "value": "The § 12-20-50(C) holding-company reduction applies to the stated increases in capital on January 1, 2003, and thereafter."
            },
            "filing_rule.corporate_license_fee": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c020.php",
              "cell_locator": "SC.llc.filing_rule.corporate_license_fee",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_license_fee",
              "value": "Covered corporations file an annual report with the Department of Revenue by the stated fourth-month deadline."
            },
            "tax_regime.corporate_license_fee": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c020.php",
              "cell_locator": "SC.llc.tax_regime.corporate_license_fee",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_license_fee",
              "value": "Every corporation required to file the annual report pays the corporate license fee, which Chapter 20 deems a tax."
            },
            "treatment.corporate_license_fee": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c020.php",
              "cell_locator": "SC.llc.treatment.corporate_license_fee",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_license_fee",
              "value": "A qualifying holding company may reduce the specified paid-in capital surplus, while § 12-20-50(A) still states the annual fee and minimum."
            }
          },
          "jurisdiction": "SC",
          "last_checked": "2026-10-02",
          "official_source_url": "https://www.scstatehouse.gov/code/t12c020.php",
          "state": "South Carolina"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-23": {
      "field_definitions": {
        "base_tax_locator.corporate_net_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporate_net_income_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporate_net_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_net_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_net_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_net_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-23",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporate_net_income_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.base_tax_locator.corporate_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_net_income_tax",
              "value": "Article IV §§401(3) and 402(b) locate the taxable-income base and dated rate schedule."
            },
            "does_not_reach.corporate_net_income_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.does_not_reach.corporate_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_net_income_tax",
              "value": "For tax years beginning after 1990, the stated dividend modification is limited to §78 amounts and qualifying foreign-corporation dividends."
            },
            "effective_period.corporate_net_income_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.effective_period.corporate_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_net_income_tax",
              "value": "The Article IV rate schedule states an ongoing period beginning January 1, 2031, after its intervening dated periods."
            },
            "filing_rule.corporate_net_income_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.filing_rule.corporate_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_net_income_tax",
              "value": "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."
            },
            "tax_regime.corporate_net_income_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.tax_regime.corporate_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_net_income_tax",
              "value": "Article IV imposes an excise tax on a corporation exercising listed Pennsylvania privileges."
            },
            "treatment.corporate_net_income_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.treatment.corporate_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_net_income_tax",
              "value": "Corporate taxable income receives the dividend modification stated in §401(3)1(b)."
            }
          },
          "jurisdiction": "PA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
          "state": "Pennsylvania"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-24": {
      "field_definitions": {
        "base_tax_locator.corporate_net_worth_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporate_net_worth_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporate_net_worth_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporate_net_worth_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporate_net_worth_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporate_net_worth_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-24",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporate_net_worth_tax": {
              "cell_citation_url": "https://dor.georgia.gov/document/document/2025-it611-corporate-income-tax-instruction-booklet/download",
              "cell_locator": "GA.llc.base_tax_locator.corporate_net_worth_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporate_net_worth_tax",
              "value": "The corporate net-worth-tax base and table are located in O.C.G.A. §§ 48-13-71 through 48-13-73 and the IT-611 net-worth schedules."
            },
            "does_not_reach.corporate_net_worth_tax": {
              "cell_citation_url": "https://dor.georgia.gov/document/document/2025-it611-corporate-income-tax-instruction-booklet/download",
              "cell_locator": "GA.llc.does_not_reach.corporate_net_worth_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporate_net_worth_tax",
              "value": "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."
            },
            "effective_period.corporate_net_worth_tax": {
              "cell_citation_url": "https://dor.georgia.gov/document/document/2025-it611-corporate-income-tax-instruction-booklet/download",
              "cell_locator": "GA.llc.effective_period.corporate_net_worth_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporate_net_worth_tax",
              "value": "No effective or sunset period for the current corporate net-worth-tax regime was stated in the searched official materials."
            },
            "filing_rule.corporate_net_worth_tax": {
              "cell_citation_url": "https://dor.georgia.gov/document/document/2025-it611-corporate-income-tax-instruction-booklet/download",
              "cell_locator": "GA.llc.filing_rule.corporate_net_worth_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporate_net_worth_tax",
              "value": "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."
            },
            "tax_regime.corporate_net_worth_tax": {
              "cell_citation_url": "https://dor.georgia.gov/taxes/taxes-corporations",
              "cell_locator": "GA.llc.tax_regime.corporate_net_worth_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporate_net_worth_tax",
              "value": "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."
            },
            "treatment.corporate_net_worth_tax": {
              "cell_citation_url": "https://dor.georgia.gov/limited-liability-companies-faq",
              "cell_locator": "GA.llc.treatment.corporate_net_worth_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporate_net_worth_tax",
              "value": "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."
            }
          },
          "jurisdiction": "GA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://dor.georgia.gov/taxes/taxes-corporations",
          "state": "Georgia"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-25": {
      "field_definitions": {
        "base_tax_locator.corporation_business_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporation_business_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporation_business_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporation_business_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporation_business_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporation_business_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-25",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporation_business_tax": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/cbt/cbt100ins.pdf",
              "cell_locator": "NJ.llc.base_tax_locator.corporation_business_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_business_tax",
              "value": "The investment-company base is located at N.J.S.A. 54:10A-5(d) and the current CBT-100 instructions, Schedule A, Part III, line 2a."
            },
            "does_not_reach.corporation_business_tax": {
              "cell_citation_url": "https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1/51481/52550",
              "cell_locator": "NJ.llc.does_not_reach.corporation_business_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_business_tax",
              "value": "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."
            },
            "effective_period.corporation_business_tax": {
              "cell_citation_url": "https://lis.njleg.state.nj.us/nxt/gateway.dll/statutes/1/51481/52550",
              "cell_locator": "NJ.llc.effective_period.corporation_business_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_business_tax",
              "value": "The captive-investment-company limitation applies to privilege periods ending on and after July 31, 2023."
            },
            "filing_rule.corporation_business_tax": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/cbt/cbt100ins.pdf",
              "cell_locator": "NJ.llc.filing_rule.corporation_business_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_business_tax",
              "value": "Every corporation acquiring taxable status in New Jersey must file a Corporation Business Tax return."
            },
            "tax_regime.corporation_business_tax": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/corp_over.shtml",
              "cell_locator": "NJ.llc.tax_regime.corporation_business_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_business_tax",
              "value": "The Corporation Business Tax is a franchise tax on domestic corporations and taxable foreign corporations."
            },
            "treatment.corporation_business_tax": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/cbt/cbt100ins.pdf",
              "cell_locator": "NJ.llc.treatment.corporation_business_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_business_tax",
              "value": "A qualifying noncaptive investment company enters 40% of the ordinary tax-base line; the current instructions separately require the minimum-tax computation."
            }
          },
          "jurisdiction": "NJ",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.nj.gov/treasury/taxation/corp_over.shtml",
          "state": "New Jersey"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-26": {
      "field_definitions": {
        "base_tax_locator.corporation_business_tax_capital_base": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporation_business_tax_capital_base": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporation_business_tax_capital_base": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporation_business_tax_capital_base": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporation_business_tax_capital_base": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporation_business_tax_capital_base": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-26",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporation_business_tax_capital_base": {
              "cell_citation_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
              "cell_locator": "CT.llc.base_tax_locator.corporation_business_tax_capital_base",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_business_tax_capital_base",
              "value": "Rate, base, subtraction, apportionment, minimum and cap: § 12-219(a)(1)."
            },
            "does_not_reach.corporation_business_tax_capital_base": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_208.htm",
              "cell_locator": "CT.llc.does_not_reach.corporation_business_tax_capital_base",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_business_tax_capital_base",
              "value": "Section 12-219a separately apportions investments other than private-corporation stock, plus cash, credits and other intangible assets."
            },
            "effective_period.corporation_business_tax_capital_base": {
              "cell_citation_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
              "cell_locator": "CT.llc.effective_period.corporation_business_tax_capital_base",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_business_tax_capital_base",
              "value": "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."
            },
            "filing_rule.corporation_business_tax_capital_base": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_208.htm",
              "cell_locator": "CT.llc.filing_rule.corporation_business_tax_capital_base",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_business_tax_capital_base",
              "value": "Each company subject to the tax must render the commissioner an annual return."
            },
            "tax_regime.corporation_business_tax_capital_base": {
              "cell_citation_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
              "cell_locator": "CT.llc.tax_regime.corporation_business_tax_capital_base",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_business_tax_capital_base",
              "value": "A company subject to chapter 208 pays the larger of the § 12-214 tax and the capital-base calculation in § 12-219(a)."
            },
            "treatment.corporation_business_tax_capital_base": {
              "cell_citation_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
              "cell_locator": "CT.llc.treatment.corporation_business_tax_capital_base",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_business_tax_capital_base",
              "value": "Private-corporation stock holdings are subtracted from the capital-base calculation under § 12-219(a)(1)(ii)."
            }
          },
          "jurisdiction": "CT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
          "state": "Connecticut"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-27": {
      "field_definitions": {
        "base_tax_locator.corporation_business_tax_net_income": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporation_business_tax_net_income": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporation_business_tax_net_income": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporation_business_tax_net_income": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporation_business_tax_net_income": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporation_business_tax_net_income": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-27",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporation_business_tax_net_income": {
              "cell_citation_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
              "cell_locator": "CT.llc.base_tax_locator.corporation_business_tax_net_income",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_business_tax_net_income",
              "value": "Rate and imposition: § 12-214(a)(1); net-income deductions: § 12-217."
            },
            "does_not_reach.corporation_business_tax_net_income": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_208.htm",
              "cell_locator": "CT.llc.does_not_reach.corporation_business_tax_net_income",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_business_tax_net_income",
              "value": "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."
            },
            "effective_period.corporation_business_tax_net_income": {
              "cell_citation_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
              "cell_locator": "CT.llc.effective_period.corporation_business_tax_net_income",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_business_tax_net_income",
              "value": "Section 12-214(a)(1) states the current net-income rate for income years beginning on or after January 1, 2000."
            },
            "filing_rule.corporation_business_tax_net_income": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_208.htm",
              "cell_locator": "CT.llc.filing_rule.corporation_business_tax_net_income",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_business_tax_net_income",
              "value": "Each company subject to the tax must render the commissioner an annual return."
            },
            "tax_regime.corporation_business_tax_net_income": {
              "cell_citation_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
              "cell_locator": "CT.llc.tax_regime.corporation_business_tax_net_income",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_business_tax_net_income",
              "value": "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."
            },
            "treatment.corporation_business_tax_net_income": {
              "cell_citation_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
              "cell_locator": "CT.llc.treatment.corporation_business_tax_net_income",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_business_tax_net_income",
              "value": "Dividend income receives the quoted deduction in computing net income, with a partial limitation for certain below-20% domestic-corporation holdings."
            }
          },
          "jurisdiction": "CT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.cga.ct.gov/2026/sup/chap_208.htm",
          "state": "Connecticut"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-28": {
      "field_definitions": {
        "base_tax_locator.corporation_excise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporation_excise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporation_excise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporation_excise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporation_excise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporation_excise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-28",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporation_excise_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
              "cell_locator": "OR.llc.base_tax_locator.corporation_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_excise_tax",
              "value": "The excise-tax rate, imposition, minimum tax and dividend modification are located in ORS 317.061, 317.070, 317.090 and 317.267."
            },
            "does_not_reach.corporation_excise_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
              "cell_locator": "OR.llc.does_not_reach.corporation_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_excise_tax",
              "value": "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."
            },
            "effective_period.corporation_excise_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
              "cell_locator": "OR.llc.effective_period.corporation_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_excise_tax",
              "value": "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."
            },
            "filing_rule.corporation_excise_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
              "cell_locator": "OR.llc.filing_rule.corporation_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_excise_tax",
              "value": "A chapter 317 or 318 return is due on the 15th day of the month following the corresponding federal-return due date."
            },
            "tax_regime.corporation_excise_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
              "cell_locator": "OR.llc.tax_regime.corporation_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_excise_tax",
              "value": "Oregon imposes the Corporation Excise Tax under ORS 317.070 on the corporations and Oregon income stated in that provision."
            },
            "treatment.corporation_excise_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
              "cell_locator": "OR.llc.treatment.corporation_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_excise_tax",
              "value": "A corporate-classified holding LLC receives different base treatment through the statutory subtraction for qualifying dividends included in federal taxable income."
            }
          },
          "jurisdiction": "OR",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
          "state": "Oregon"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-29": {
      "field_definitions": {
        "base_tax_locator.corporation_franchise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporation_franchise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporation_franchise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporation_franchise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporation_franchise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporation_franchise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-29",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporation_franchise_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
              "cell_locator": "CA.llc.base_tax_locator.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_franchise_tax",
              "value": "Rate: R&TC § 23151; minimum franchise tax: § 23153; S corporation rate: § 23802(b)(1); alternative minimum tax: Chapter 2.5 (§§ 23400-23459)."
            },
            "does_not_reach.corporation_franchise_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
              "cell_locator": "CA.llc.does_not_reach.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_franchise_tax",
              "value": "§ 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."
            },
            "effective_period.corporation_franchise_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
              "cell_locator": "CA.llc.effective_period.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_franchise_tax",
              "value": "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."
            },
            "filing_rule.corporation_franchise_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.2.&chapter=2.&article=",
              "cell_locator": "CA.llc.filing_rule.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_franchise_tax",
              "value": "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."
            },
            "tax_regime.corporation_franchise_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
              "cell_locator": "CA.llc.tax_regime.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_franchise_tax",
              "value": "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."
            },
            "treatment.corporation_franchise_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
              "cell_locator": "CA.llc.treatment.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_franchise_tax",
              "value": "§ 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."
            }
          },
          "jurisdiction": "CA",
          "last_checked": "2026-10-02",
          "official_source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=2.&article=",
          "state": "California"
        },
        {
          "cells": {
            "base_tax_locator.corporation_franchise_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27",
              "cell_locator": "WI.llc.base_tax_locator.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_franchise_tax",
              "value": "Imposition and rate: Wis. Stat. § 71.23(2); Wis. Stat. § 71.27(2); Wisconsin net income and allocation/apportionment: § 71.25."
            },
            "does_not_reach.corporation_franchise_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.22",
              "cell_locator": "WI.llc.does_not_reach.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_franchise_tax",
              "value": "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."
            },
            "effective_period.corporation_franchise_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27",
              "cell_locator": "WI.llc.effective_period.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_franchise_tax",
              "value": "Current § 71.23(2) applies with the 7.9% rate stated in Wis. Stat. § 71.27(2)."
            },
            "filing_rule.corporation_franchise_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.24",
              "cell_locator": "WI.llc.filing_rule.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_franchise_tax",
              "value": "A nonexempt corporation files by its federal return due date, without extension, and reports each item of nontaxable income."
            },
            "tax_regime.corporation_franchise_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.23",
              "cell_locator": "WI.llc.tax_regime.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_franchise_tax",
              "value": "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."
            },
            "treatment.corporation_franchise_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.25",
              "cell_locator": "WI.llc.treatment.corporation_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_franchise_tax",
              "value": "The listed holding-income categories are presumed apportionable when the statutory unitary or integral-investment conditions are met."
            }
          },
          "jurisdiction": "WI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.23",
          "state": "Wisconsin"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-30": {
      "field_definitions": {
        "base_tax_locator.corporation_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
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        "effective_period.corporation_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporation_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporation_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporation_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-30",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporation_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=3.&article=",
              "cell_locator": "CA.llc.base_tax_locator.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_income_tax",
              "value": "The rate is set by reference to R&TC § 23151 under § 23501(c); S corporations: § 23802(b)(1); alternative minimum tax for Chapter 3 taxpayers: § 23455(a)(2)."
            },
            "does_not_reach.corporation_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article=",
              "cell_locator": "CA.llc.does_not_reach.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_income_tax",
              "value": "§ 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."
            },
            "effective_period.corporation_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=3.&article=",
              "cell_locator": "CA.llc.effective_period.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_income_tax",
              "value": "§ 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."
            },
            "filing_rule.corporation_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.2.&chapter=2.&article=",
              "cell_locator": "CA.llc.filing_rule.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_income_tax",
              "value": "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))."
            },
            "tax_regime.corporation_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=3.&article=",
              "cell_locator": "CA.llc.tax_regime.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_income_tax",
              "value": "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."
            },
            "treatment.corporation_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=1.&article=",
              "cell_locator": "CA.llc.treatment.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_income_tax",
              "value": "§ 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."
            }
          },
          "jurisdiction": "CA",
          "last_checked": "2026-10-02",
          "official_source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=3.&article=",
          "state": "California"
        },
        {
          "cells": {
            "base_tax_locator.corporation_income_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c019/index.html",
              "cell_locator": "DE.llc.base_tax_locator.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_income_tax",
              "value": "The rate is set in 30 Del. C. § 1902(a); taxable income is computed, allocated and apportioned under 30 Del. C. § 1903."
            },
            "does_not_reach.corporation_income_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c019/index.html",
              "cell_locator": "DE.llc.does_not_reach.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_income_tax",
              "value": "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."
            },
            "effective_period.corporation_income_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c019/index.html",
              "cell_locator": "DE.llc.effective_period.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_income_tax",
              "value": "Chapter 19 states the corporation income tax was first effective for income earned after December 31, 1957 (30 Del. C. § 1907)."
            },
            "filing_rule.corporation_income_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c019/index.html",
              "cell_locator": "DE.llc.filing_rule.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_income_tax",
              "value": "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."
            },
            "tax_regime.corporation_income_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c019/index.html",
              "cell_locator": "DE.llc.tax_regime.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_income_tax",
              "value": "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."
            },
            "treatment.corporation_income_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c019/index.html",
              "cell_locator": "DE.llc.treatment.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_income_tax",
              "value": "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."
            }
          },
          "jurisdiction": "DE",
          "last_checked": "2026-10-02",
          "official_source_url": "https://delcode.delaware.gov/title30/c019/index.html",
          "state": "Delaware"
        },
        {
          "cells": {
            "base_tax_locator.corporation_income_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=55419",
              "cell_locator": "KY.llc.base_tax_locator.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_income_tax",
              "value": "The corporation income-tax rate is located at KRS 141.040(2)."
            },
            "does_not_reach.corporation_income_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57915",
              "cell_locator": "KY.llc.does_not_reach.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_income_tax",
              "value": "The dividend exclusion is limited to dividend income; the same calculation expressly includes interest from sister-state obligations."
            },
            "effective_period.corporation_income_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57915",
              "cell_locator": "KY.llc.effective_period.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_income_tax",
              "value": "The current corporate gross- and net-income calculation in KRS 141.039 is effective July 15, 2026."
            },
            "filing_rule.corporation_income_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=29084",
              "cell_locator": "KY.llc.filing_rule.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_income_tax",
              "value": "Income returns are due April 15 for calendar-year taxpayers or the fifteenth day of the fourth month after a fiscal year closes."
            },
            "tax_regime.corporation_income_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=55419",
              "cell_locator": "KY.llc.tax_regime.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_income_tax",
              "value": "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."
            },
            "treatment.corporation_income_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57915",
              "cell_locator": "KY.llc.treatment.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_income_tax",
              "value": "A corporation-classified holding LLC remains within corporation income tax, but all dividend income is excluded from the Kentucky gross-income calculation."
            }
          },
          "jurisdiction": "KY",
          "last_checked": "2026-10-02",
          "official_source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=55419",
          "state": "Kentucky"
        },
        {
          "cells": {
            "base_tax_locator.corporation_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors318.html",
              "cell_locator": "OR.llc.base_tax_locator.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_income_tax",
              "value": "The income-tax imposition and incorporation rule are in ORS 318.020 and 318.031; chapter 317 contains the rate and dividend modification."
            },
            "does_not_reach.corporation_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
              "cell_locator": "OR.llc.does_not_reach.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_income_tax",
              "value": "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."
            },
            "effective_period.corporation_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors318.html",
              "cell_locator": "OR.llc.effective_period.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_income_tax",
              "value": "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."
            },
            "filing_rule.corporation_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
              "cell_locator": "OR.llc.filing_rule.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_income_tax",
              "value": "A chapter 317 or 318 return is due on the 15th day of the month following the corresponding federal-return due date."
            },
            "tax_regime.corporation_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors318.html",
              "cell_locator": "OR.llc.tax_regime.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_income_tax",
              "value": "Oregon imposes the Corporation Income Tax under ORS 318.020(1) on the corporations and Oregon income stated in that provision."
            },
            "treatment.corporation_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors317.html",
              "cell_locator": "OR.llc.treatment.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_income_tax",
              "value": "A corporate-classified holding LLC receives different base treatment through the statutory subtraction for qualifying dividends included in federal taxable income."
            }
          },
          "jurisdiction": "OR",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors318.html",
          "state": "Oregon"
        },
        {
          "cells": {
            "base_tax_locator.corporation_income_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27",
              "cell_locator": "WI.llc.base_tax_locator.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_income_tax",
              "value": "Imposition and rate: Wis. Stat. § 71.23(1); Wis. Stat. § 71.27(1); Wisconsin net income and allocation/apportionment: § 71.25."
            },
            "does_not_reach.corporation_income_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.22",
              "cell_locator": "WI.llc.does_not_reach.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_income_tax",
              "value": "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."
            },
            "effective_period.corporation_income_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.27",
              "cell_locator": "WI.llc.effective_period.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_income_tax",
              "value": "Current § 71.23(1) applies with the 7.9% rate stated in Wis. Stat. § 71.27(1)."
            },
            "filing_rule.corporation_income_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.24",
              "cell_locator": "WI.llc.filing_rule.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_income_tax",
              "value": "A nonexempt corporation files by its federal return due date, without extension, and reports each item of nontaxable income."
            },
            "tax_regime.corporation_income_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.23",
              "cell_locator": "WI.llc.tax_regime.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_income_tax",
              "value": "The income tax reaches a corporation not subject to the franchise tax that owns Wisconsin property or has Wisconsin-source or attributable income."
            },
            "treatment.corporation_income_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.25",
              "cell_locator": "WI.llc.treatment.corporation_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_income_tax",
              "value": "The listed holding-income categories are presumed apportionable when the statutory unitary or integral-investment conditions are met."
            }
          },
          "jurisdiction": "WI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.23",
          "state": "Wisconsin"
        }
      ],
      "scope_label": "5 jurisdictions"
    },
    "state-tax-31": {
      "field_definitions": {
        "base_tax_locator.corporation_net_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.corporation_net_income_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.corporation_net_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.corporation_net_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.corporation_net_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.corporation_net_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-31",
      "rows": [
        {
          "cells": {
            "base_tax_locator.corporation_net_income_tax": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.base_tax_locator.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_net_income_tax",
              "value": "The corporation net-income-tax base and rate schedule are located at AS 43.20.011(e); no amount is transcribed here."
            },
            "does_not_reach.corporation_net_income_tax": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.does_not_reach.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_net_income_tax",
              "value": "Interest earned on property in Alaska does not by itself establish a taxable or business situs in Alaska."
            },
            "effective_period.corporation_net_income_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.effective_period.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_net_income_tax",
              "value": "The current Form 6000 tax-rate table identifies its operative period as tax years beginning on or after August 26, 2013."
            },
            "filing_rule.corporation_net_income_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.filing_rule.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_net_income_tax",
              "value": "A federally corporate LLC files under the corporate instructions, and the Alaska return is due in the month following the federal due date."
            },
            "tax_regime.corporation_net_income_tax": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.tax_regime.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_net_income_tax",
              "value": "Alaska imposes corporation net income tax on every corporation's taxable income derived from Alaska sources."
            },
            "treatment.corporation_net_income_tax": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.treatment.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_net_income_tax",
              "value": "Qualifying foreign-corporation dividends and royalties receive statutory exclusions from taxable income; Chapter 20 states no general holding-entity exemption."
            }
          },
          "jurisdiction": "AK",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
          "state": "Alaska"
        },
        {
          "cells": {
            "base_tax_locator.corporation_net_income_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-24-4/",
              "cell_locator": "WV.llc.base_tax_locator.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.corporation_net_income_tax",
              "value": "The current corporation net income-tax imposition and rate are located in W. Va. Code §11-24-4(8)."
            },
            "does_not_reach.corporation_net_income_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-24-4/",
              "cell_locator": "WV.llc.does_not_reach.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.corporation_net_income_tax",
              "value": "No special statutory limit for holding or passive entities was located in the complete corporation net income tax article."
            },
            "effective_period.corporation_net_income_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-24-4/",
              "cell_locator": "WV.llc.effective_period.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.corporation_net_income_tax",
              "value": "The current corporation net income-tax paragraph applies to taxable periods beginning on or after January 1, 2014."
            },
            "filing_rule.corporation_net_income_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-24-13/",
              "cell_locator": "WV.llc.filing_rule.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.corporation_net_income_tax",
              "value": "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."
            },
            "tax_regime.corporation_net_income_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-24-4/",
              "cell_locator": "WV.llc.tax_regime.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.corporation_net_income_tax",
              "value": "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."
            },
            "treatment.corporation_net_income_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-24-4/",
              "cell_locator": "WV.llc.treatment.corporation_net_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.corporation_net_income_tax",
              "value": "The generally applicable corporation net income tax applies; no holding-entity carve-out was located in the complete article."
            }
          },
          "jurisdiction": "WV",
          "last_checked": "2026-10-03",
          "official_source_url": "https://code.wvlegislature.gov/11-24-4/",
          "state": "West Virginia"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-32": {
      "field_definitions": {
        "base_tax_locator.digital_business_entity_franchise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.digital_business_entity_franchise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.digital_business_entity_franchise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.digital_business_entity_franchise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.digital_business_entity_franchise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.digital_business_entity_franchise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-32",
      "rows": [
        {
          "cells": {
            "base_tax_locator.digital_business_entity_franchise_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.base_tax_locator.digital_business_entity_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.digital_business_entity_franchise_tax",
              "value": "The Digital Business Entity Franchise Tax base and limits are located at 32 V.S.A. § 5832a(a)–(b)."
            },
            "does_not_reach.digital_business_entity_franchise_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.does_not_reach.digital_business_entity_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.digital_business_entity_franchise_tax",
              "value": "The regime does not reach a nonelecting entity or one that fails the full-year digital-business-entity conditions."
            },
            "effective_period.digital_business_entity_franchise_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.effective_period.digital_business_entity_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.digital_business_entity_franchise_tax",
              "value": "The Digital Business Entity Franchise Tax took effect January 1, 2010."
            },
            "filing_rule.digital_business_entity_franchise_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.filing_rule.digital_business_entity_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.digital_business_entity_franchise_tax",
              "value": "The franchise tax is reported and paid in the stated corporate-tax manner, with a federal return copy supplied to the Commissioner."
            },
            "tax_regime.digital_business_entity_franchise_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.tax_regime.digital_business_entity_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.digital_business_entity_franchise_tax",
              "value": "An annual franchise tax is imposed on every business entity that qualifies and elects as a digital business entity."
            },
            "treatment.digital_business_entity_franchise_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.treatment.digital_business_entity_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.digital_business_entity_franchise_tax",
              "value": "Every qualifying electing business entity is subject to the annual franchise tax; no holding- or passive-entity carveout is stated."
            }
          },
          "jurisdiction": "VT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
          "state": "Vermont"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-33": {
      "field_definitions": {
        "base_tax_locator.economic_development_surcharge": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.economic_development_surcharge": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.economic_development_surcharge": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.economic_development_surcharge": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.economic_development_surcharge": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.economic_development_surcharge": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-33",
      "rows": [
        {
          "cells": {
            "base_tax_locator.economic_development_surcharge": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/77.94",
              "cell_locator": "WI.llc.base_tax_locator.economic_development_surcharge",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.economic_development_surcharge",
              "value": "Section 77.94 sets 3% of corporate gross tax liability or 0.2% of tax-option-corporation net income, subject to a $25 minimum and $9,800 maximum."
            },
            "does_not_reach.economic_development_surcharge": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/77.93",
              "cell_locator": "WI.llc.does_not_reach.economic_development_surcharge",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.economic_development_surcharge",
              "value": "The rule excludes an exempt corporation with no reportable unrelated business income; a federally disregarded single-owner entity is not separate under this subchapter."
            },
            "effective_period.economic_development_surcharge": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/77.96",
              "cell_locator": "WI.llc.effective_period.economic_development_surcharge",
              "publish_status": "publish_ready",
              "source_field": "effective_period.economic_development_surcharge",
              "value": "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."
            },
            "filing_rule.economic_development_surcharge": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/77.96",
              "cell_locator": "WI.llc.filing_rule.economic_development_surcharge",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.economic_development_surcharge",
              "value": "A subject person files an accurate gross-tax-liability statement by the chapter 71 filing deadline, including extensions."
            },
            "tax_regime.economic_development_surcharge": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/77.93",
              "cell_locator": "WI.llc.tax_regime.economic_development_surcharge",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.economic_development_surcharge",
              "value": "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."
            },
            "treatment.economic_development_surcharge": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/77.93",
              "cell_locator": "WI.llc.treatment.economic_development_surcharge",
              "publish_status": "publish_ready",
              "source_field": "treatment.economic_development_surcharge",
              "value": "A qualifying corporation is subject based on gross receipts from all activities; § 77.93 states no special holding-entity treatment."
            }
          },
          "jurisdiction": "WI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://docs.legis.wisconsin.gov/document/statutes/77.93",
          "state": "Wisconsin"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-34": {
      "field_definitions": {
        "base_tax_locator.electing_pass_through_entity_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.electing_pass_through_entity_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.electing_pass_through_entity_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.electing_pass_through_entity_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.electing_pass_through_entity_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.electing_pass_through_entity_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-34",
      "rows": [
        {
          "cells": {
            "base_tax_locator.electing_pass_through_entity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
              "cell_locator": "OH.llc.base_tax_locator.electing_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.electing_pass_through_entity_tax",
              "value": "The electing tax's rate is set in R.C. 5747.38(B); the annual return is R.C. 5747.42(A)(2)."
            },
            "does_not_reach.electing_pass_through_entity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
              "cell_locator": "OH.llc.does_not_reach.electing_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.electing_pass_through_entity_tax",
              "value": "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."
            },
            "effective_period.electing_pass_through_entity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
              "cell_locator": "OH.llc.effective_period.electing_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.electing_pass_through_entity_tax",
              "value": "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."
            },
            "filing_rule.electing_pass_through_entity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
              "cell_locator": "OH.llc.filing_rule.electing_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.electing_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.electing_pass_through_entity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
              "cell_locator": "OH.llc.tax_regime.electing_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.electing_pass_through_entity_tax",
              "value": "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."
            },
            "treatment.electing_pass_through_entity_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
              "cell_locator": "OH.llc.treatment.electing_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.electing_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "OH",
          "last_checked": "2026-10-02",
          "official_source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.38",
          "state": "Ohio"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-35": {
      "field_definitions": {
        "base_tax_locator.elective_pass_through_entity_excise": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.elective_pass_through_entity_excise": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.elective_pass_through_entity_excise": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.elective_pass_through_entity_excise": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.elective_pass_through_entity_excise": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.elective_pass_through_entity_excise": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-35",
      "rows": [
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section2",
              "cell_locator": "MA.llc.base_tax_locator.elective_pass_through_entity_excise",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_excise",
              "value": "The qualified-income definition and elective excise measure are located in Chapter 63D §§ 1 and 2."
            },
            "does_not_reach.elective_pass_through_entity_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section1",
              "cell_locator": "MA.llc.does_not_reach.elective_pass_through_entity_excise",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_excise",
              "value": "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."
            },
            "effective_period.elective_pass_through_entity_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section3",
              "cell_locator": "MA.llc.effective_period.elective_pass_through_entity_excise",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_excise",
              "value": "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."
            },
            "filing_rule.elective_pass_through_entity_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section4",
              "cell_locator": "MA.llc.filing_rule.elective_pass_through_entity_excise",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_excise",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section2",
              "cell_locator": "MA.llc.tax_regime.elective_pass_through_entity_excise",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_excise",
              "value": "An eligible pass-through entity may elect the Chapter 63D excise on qualified income taxable in Massachusetts."
            },
            "treatment.elective_pass_through_entity_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section2",
              "cell_locator": "MA.llc.treatment.elective_pass_through_entity_excise",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_excise",
              "value": "Chapter 63D states the elective qualified-income rule but no distinct treatment for a holding or passive eligible pass-through entity."
            }
          },
          "jurisdiction": "MA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63D/Section2",
          "state": "Massachusetts"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-36": {
      "field_definitions": {
        "base_tax_locator.elective_pass_through_entity_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.elective_pass_through_entity_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.elective_pass_through_entity_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.elective_pass_through_entity_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.elective_pass_through_entity_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.elective_pass_through_entity_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-05",
      "matrix_id": "pp-holding-entity-tax:state-tax-36",
      "rows": [
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective pass-through-entity tax rate, calculation, and apportionment locators are stated in Ala. Code § 40-18-24.4(e)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "The elective pass-through-entity tax provisions state no holding-income or holding-entity limit to the regime's scope."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The elective pass-through-entity tax election is available for tax years beginning on or after January 1, 2021."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "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."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
              "cell_locator": "AL.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "No holding- or passive-entity exemption, deduction, or alternative tax treatment is stated for the elective pass-through-entity tax."
            }
          },
          "jurisdiction": "AL",
          "last_checked": "2026-10-03",
          "official_source_url": "https://alison.legislature.state.al.us/graphql?query=query%7BcodesOfAlabama%28where%3A%7BdisplayId%3A%7Blike%3A%2240-18-%25%22%7D%7D%2Climit%3A500%2Coffset%3A0%29%7Bdata%7Bid%20displayId%20title%20effectiveDate%20supersessionDate%20content%20history%7D%20count%7D%7D",
          "state": "Alabama"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FAssembly%2FMeeting+Attachments%2F040%2F25167%2FE.4.a+DFA+AR+Elective+Pass-Through+Entity+Tax+Rule+and+Act+362+of+2021.pdf",
              "cell_locator": "AR.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The ordinary PTE rate and the net-capital-gain half-rate rule are located at Ark. Code Ann. § 26-65-103(b)(1)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FAssembly%2FMeeting+Attachments%2F040%2F25167%2FE.4.a+DFA+AR+Elective+Pass-Through+Entity+Tax+Rule+and+Act+362+of+2021.pdf",
              "cell_locator": "AR.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "The half-rate treatment is confined to net capital gain; the main levy applies to the affected entity's net taxable business income."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FAssembly%2FMeeting+Attachments%2F040%2F25167%2FE.4.a+DFA+AR+Elective+Pass-Through+Entity+Tax+Rule+and+Act+362+of+2021.pdf",
              "cell_locator": "AR.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "Act 362's elective PTE provisions apply to tax years beginning on or after January 1, 2022."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
              "cell_locator": "AR.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
              "cell_locator": "AR.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "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."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://arkleg.state.ar.us/Home/FTPDocument?path=%2FAssembly%2FMeeting+Attachments%2F040%2F25167%2FE.4.a+DFA+AR+Elective+Pass-Through+Entity+Tax+Rule+and+Act+362+of+2021.pdf",
              "cell_locator": "AR.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "AR",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
          "state": "Arkansas"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01014.htm",
              "cell_locator": "AZ.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective PTE tax base and rate locator is A.R.S. § 43-1014(A)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01014.htm",
              "cell_locator": "AZ.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "The election excludes income attributable to ineligible owner types and individual, estate, or trust owners who opt out."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01014.htm",
              "cell_locator": "AZ.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The entity-level election applies to taxable years beginning after December 31, 2021."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01014.htm",
              "cell_locator": "AZ.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "The election is made on the business return, and an electing partnership or S corporation pays estimated tax as necessary."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01014.htm",
              "cell_locator": "AZ.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "Eligible owners of a federally partnership- or S-corporation-treated business may elect Arizona entity-level income tax."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.azleg.gov/ars/43/01014.htm",
              "cell_locator": "AZ.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "The elective PTE provisions state no separate holding- or passive-entity treatment."
            }
          },
          "jurisdiction": "AZ",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.azleg.gov/ars/43/01014.htm",
          "state": "Arizona"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
              "cell_locator": "CA.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The rate is in R&TC § 19910(a)(1), qualified net income is defined in § 19910(a)(2), and payment dates are in § 19914."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
              "cell_locator": "CA.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "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."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
              "cell_locator": "CA.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "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."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
              "cell_locator": "CA.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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))."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
              "cell_locator": "CA.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "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."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
              "cell_locator": "CA.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "CA",
          "last_checked": "2026-10-02",
          "official_source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.4.1.&chapter=&article=",
          "state": "California"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective PTE tax base and rate cross-reference are located in §39-22-344(1)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "No special statutory limit for holding or passive entities was located in the complete SALT Parity Act subpart."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The annual election applies for income-tax years beginning on or after January 1, 2018, but only while the federal §164 deduction limitation exists."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "The S corporation or partnership makes the annual election on its §39-22-601 return, and that filed election binds all electing owners."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "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."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://olls.info/crs/crs2026-title-39.pdf",
              "cell_locator": "CO.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "The elective tax uses the stated owner-share income base; no holding-entity carve-out from that base was located in the complete subpart."
            }
          },
          "jurisdiction": "CO",
          "last_checked": "2026-10-03",
          "official_source_url": "https://olls.info/crs/crs2026-title-39.pdf",
          "state": "Colorado"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
              "cell_locator": "CT.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "Rate and tax base: § 12-699(c)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
              "cell_locator": "CT.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "Affected business entity excludes a qualifying publicly traded partnership that agrees to file the described annual unitholder return."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
              "cell_locator": "CT.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The elective regime applies for taxable years beginning on or after January 1, 2024."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
              "cell_locator": "CT.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
              "cell_locator": "CT.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "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)."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
              "cell_locator": "CT.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "No holding-entity or passive-income carve-out was located in chapter 228z; the regime is elective."
            }
          },
          "jurisdiction": "CT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.cga.ct.gov/current/pub/chap_228z.htm",
          "state": "Connecticut"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The qualified-member Hawaii taxable-income base and rate are located in §235-51.5(b); no amount is transcribed here."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "The statutory definitions exclude publicly traded partnerships and limit qualified members to individuals, trusts, and estates."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The elective pass-through entity tax applies to taxable years beginning after December 31, 2022."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "An electing partnership or S corporation pays entity-level tax on qualified members' Hawaii taxable distributive shares and guaranteed payments."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "The elective base uses all qualified members' Hawaii taxable distributive shares and guaranteed payments; no holding or passive carve-out was located."
            }
          },
          "jurisdiction": "HI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
          "state": "Hawaii"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The PTET base and rate reference are located at Iowa Code § 422.16C(4)(a); no amount is transcribed here."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://revenue.iowa.gov/taxes/tax-guidance/business-income-tax/pass-through-entity-tax-ptet",
              "cell_locator": "IA.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "A publicly traded partnership and a single-member or other federally disregarded LLC cannot make their own PTET election."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://revenue.iowa.gov/taxes/tax-guidance/business-income-tax/pass-through-entity-tax-ptet",
              "cell_locator": "IA.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The election is available for qualifying tax years beginning on or after January 1, 2022 and is no longer scheduled to expire."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "A separate irrevocable election is made for each tax year, and the entity-level tax is due with the taxpayer's return."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "An electing taxpayer pays entity-level tax on its properly determined Iowa taxable income, allocated and apportioned under Department rules."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
              "cell_locator": "IA.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "IA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.legis.iowa.gov/docs/code/2026/422.html",
          "state": "Iowa"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective pass-through-entity tax base, allocation method, rate, and due-date locators are in Ind. Code § 6-3-2.1-4(a)-(b)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "The special allocation excludes the stated security-interest income and yields to business-income treatment for integrally related, operational, or working-capital investment activity."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The PTET chapter applies after 2021; the investment-partnership allocation rule applies to taxable years beginning after December 31, 2025."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "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."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
              "cell_locator": "IN.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "IN",
          "last_checked": "2026-10-03",
          "official_source_url": "https://iga.in.gov/ic/2026/Title_6/Article_3.pdf",
          "state": "Indiana"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
              "cell_locator": "KS.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective pass-through entity tax base and rate locator is K.S.A. 79-32,287(a)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0285_section/079_032_0285_k/",
              "cell_locator": "KS.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "For a partnership, the statutory definition of electing pass-through entity owner excludes a C corporation partner."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
              "cell_locator": "KS.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The entity-level tax provisions apply to taxable years commencing on or after January 1, 2022."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0286_section/079_032_0286_k/",
              "cell_locator": "KS.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "The S corporation or partnership makes the election on its filed return, and that filing binds all electing pass-through entity owners."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
              "cell_locator": "KS.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "An electing pass-through entity is subject to Kansas entity-level tax computed under K.S.A. 79-32,287(a)."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
              "cell_locator": "KS.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "The SALT Parity Act states no separate holding- or passive-entity treatment."
            }
          },
          "jurisdiction": "KS",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.kslegislature.gov/b2025_26/laws/079_000_0000_chapter/079_032_0000_article/079_032_0287_section/079_032_0287_k/",
          "state": "Kansas"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
              "cell_locator": "KY.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective PTE tax points to the tax under KRS 141.020; KRS 141.209(2)(a) is the incorporation locator."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf",
              "cell_locator": "KY.llc.does_not_reach.elective_pass_through_entity_tax",
              "note": "The official record does not state this",
              "publish_status": "typed_unknown",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "official_record_silent",
              "visible_subline": "KRS 141.209(2)(a) imposes the tax “based upon the ordinary\nincome and separately stated items of income calculated under\nKRS 141.206.” These items include all items listed on the Kentucky\nSchedule K-1 reporting distributable share income including, but\nnot limited to, interest income, dividend income, capital gains,\nguaranteed payments, and rents."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
              "cell_locator": "KY.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The election applies to taxable years beginning on or after January 1, 2022; KRS 141.209 became effective March 31, 2023."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
              "cell_locator": "KY.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
              "cell_locator": "KY.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "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."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://revenue.ky.gov/Forms/Form%20PTET%20Instructions.pdf",
              "cell_locator": "KY.llc.treatment.elective_pass_through_entity_tax",
              "note": "The official record does not state this",
              "publish_status": "typed_unknown",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "official_record_silent",
              "visible_subline": "KRS 141.209(2)(a) imposes the tax “based upon the ordinary\nincome and separately stated items of income calculated under\nKRS 141.206.” These items include all items listed on the Kentucky\nSchedule K-1 reporting distributable share income including, but\nnot limited to, interest income, dividend income, capital gains,\nguaranteed payments, and rents."
            }
          },
          "jurisdiction": "KY",
          "last_checked": "2026-10-05",
          "official_source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=53597",
          "state": "Kentucky"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
              "cell_locator": "LA.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective entity-level tax rate cross-reference is located in La. R.S. 47:287.732.2(B)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
              "cell_locator": "LA.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "An entity filing a composite partnership return under La. R.S. 47:201.1 cannot make the election for the same tax year."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
              "cell_locator": "LA.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The election applies for the elected taxable year and all succeeding taxable years until termination under the statute."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
              "cell_locator": "LA.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "The election must be made in writing within the statutory period, subject to the secretary's reasonable-cause authority for a late election."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
              "cell_locator": "LA.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "Louisiana taxes the Louisiana taxable income of an entity making the pass-through election at the rate referenced for individuals."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.legis.la.gov/legis/Law.aspx?d=101725",
              "cell_locator": "LA.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "LA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.legis.la.gov/legis/Law.aspx?d=1148883",
          "state": "Louisiana"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The qualifying-owner liability sum, income base, and individual-rate cross-reference are located in §289A.08, subd. 7a(c)-(d); no amount is transcribed here."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "A publicly traded partnership is not a qualifying entity, and the election must exclude owners who are not qualifying owners."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The election applies to taxable years beginning after 2020 and expires with federal IRC §164(b)(6)(B), without ending later audit authority."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "Minnesota imposes pass-through entity tax on a qualifying entity that makes the annual election, measured by qualifying owners' tax liabilities."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "The elective tax uses the sum of each qualifying owner's tax liability; no holding-company or passive-income carve-out was located."
            }
          },
          "jurisdiction": "MN",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
          "state": "Minnesota"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
              "cell_locator": "MT.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The PTET rate and affected-owner Montana-source-income base are located in Mont. Code Ann. § 15-30-3326(1)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
              "cell_locator": "MT.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "The complete PTET provisions state no holding-income or holding-entity limit on the universal electing-entity imposition."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
              "cell_locator": "MT.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The complete four-section PTET subpart states annual operation but no effective or sunset date in its operative text."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0270/0150-0300-0330-0270.html",
              "cell_locator": "MT.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "The election is annual, irrevocable for the year, and due by the extended return deadline; the entity designates an authorized Montana representative."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
              "cell_locator": "MT.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "Each electing partnership or S corporation pays Montana entity tax on the stated affected-owner Montana-source-income base."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
              "cell_locator": "MT.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "Every electing pass-through entity pays the entity tax under the universal imposition; complete search found no holding/passive exception."
            }
          },
          "jurisdiction": "MT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://mca.legmt.gov/bills/mca/title_0150/chapter_0300/part_0330/section_0260/0150-0300-0330-0260.html",
          "state": "Montana"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
              "cell_locator": "NC.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "Taxed-S-corporation base: § 105-131.1A(b); taxed-partnership base: § 105-154.1(b); rate: § 105-153.7."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-154.1.html",
              "cell_locator": "NC.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "A publicly traded partnership described in Code § 7704(c), or a partnership with an unlisted partner type, cannot make the election."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
              "cell_locator": "NC.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The current taxed-S-corporation and taxed-partnership election language applies to taxable years beginning on or after January 1, 2023."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
              "cell_locator": "NC.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "The election is made on the entity's timely filed return and cannot be made or revoked after that return is filed."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
              "cell_locator": "NC.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "An electing taxed S corporation or taxed partnership pays annual tax on North Carolina taxable income at the § 105-153.7 rate."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
              "cell_locator": "NC.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "No holding-entity or passive-income carve-out was located in the two election sections; the regime is elective."
            }
          },
          "jurisdiction": "NC",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-131.1A.html",
          "state": "North Carolina"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2727",
              "cell_locator": "NE.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The partnership and S-corporation PTET base and rate references are located at Neb. Rev. Stat. §§ 77-2727(6)(b) and 77-2734.01(8)(b); no amount is transcribed here."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2727",
              "cell_locator": "NE.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "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."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://revenue.nebraska.gov/tax-credits/nebraska-pass-through-entity-tax-ptet",
              "cell_locator": "NE.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The Department states that eligible partnerships and S corporations may elect PTET for tax years beginning on and after January 1, 2018."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://revenue.nebraska.gov/tax-credits/nebraska-pass-through-entity-tax-ptet",
              "cell_locator": "NE.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2727",
              "cell_locator": "NE.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "An eligible partnership or S corporation may irrevocably elect for a tax year to pay Nebraska income tax at the entity level."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2727",
              "cell_locator": "NE.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "NE",
          "last_checked": "2026-10-03",
          "official_source_url": "https://nebraskalegislature.gov/laws/statutes.php?statute=77-2727",
          "state": "Nebraska"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The entity-level tax rate and distributed-net-income base are located at NMSA 1978, § 7-3A-10(C)-(D)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "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."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The 2023 entity-level-tax amendments apply to taxable years beginning on or after January 1, 2023."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "A pass-through entity may elect annually to pay entity-level tax; the tax is imposed on distributed net income."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "The entity remains subject to elective tax, but qualifying net capital gain is removed from distributed net income."
            }
          },
          "jurisdiction": "NM",
          "last_checked": "2026-10-03",
          "official_source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
          "state": "New Mexico"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/862",
              "cell_locator": "NY.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The Article 24-A pass-through entity tax rate table is located in N.Y. Tax Law §862."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/860",
              "cell_locator": "NY.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "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."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/861",
              "cell_locator": "NY.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "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."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/865",
              "cell_locator": "NY.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "Each electing partnership and electing S corporation must file its Article 24-A return by March fifteenth following the close of the stated year."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/862",
              "cell_locator": "NY.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "Article 24-A imposes tax for each taxable year on the pass-through entity taxable income of every electing partnership and electing S corporation."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.nysenate.gov/legislation/laws/TAX/860",
              "cell_locator": "NY.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "NY",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.nysenate.gov/legislation/laws/TAX/862",
          "state": "New York"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The entity-income definition, member classes, tax calculation, and election rules are located at Title 68 §§ 2355.1P-2 and 2355.1P-4."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "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."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The current pass-through entity tax calculation applies to tax years beginning on or after January 1, 2022."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "Oklahoma levies the pass-through entity tax on each electing pass-through entity for tax years beginning on or after January 1, 2022."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
              "cell_locator": "OK.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "The elective tax applies to Oklahoma net entity income without a separately stated holding- or passive-entity treatment."
            }
          },
          "jurisdiction": "OK",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os68.pdf",
          "state": "Oklahoma"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
              "cell_locator": "UT.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective PTET base and rate reference are located at Utah Code § 59-10-1403.2(2)(a); no amount is transcribed here."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
              "cell_locator": "UT.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "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."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
              "cell_locator": "UT.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The current elective-tax section is identified in the official Code XML as amended in the 2026 General Session."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
              "cell_locator": "UT.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "Payment by the last day of the taxable year is the irrevocable, nonrefundable election, and the entity must remit by that date."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
              "cell_locator": "UT.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "A pass-through entity that is not disregarded may elect to pay tax on voluntary taxable income."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
              "cell_locator": "UT.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "UT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://le.utah.gov/xcode/Title59/Chapter10/C59-10_1800010118000101.xml",
          "state": "Utah"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
              "cell_locator": "VA.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective pass-through-entity tax rate and base are located at Va. Code § 58.1-390.3(B)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article2/",
              "cell_locator": "VA.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "The federal-obligation subtraction excludes interest on federal tax refunds, equipment-purchase contracts, and other normal business transactions."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
              "cell_locator": "VA.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "For taxable years beginning on or after January 1, 2022, a pass-through entity may make the annual election on its timely filed return."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
              "cell_locator": "VA.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
              "cell_locator": "VA.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "Virginia annually taxes the Virginia taxable income attributable to eligible owners of every pass-through entity making the annual election."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
              "cell_locator": "VA.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "The electing LLC remains subject to PTET, but qualifying U.S.- and Virginia-obligation income is subtracted through the incorporated owner-modification rules."
            }
          },
          "jurisdiction": "VA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article9/",
          "state": "Virginia"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
              "cell_locator": "WI.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "Partnership rate and base: § 71.21(6)(a), (d)1.; tax-option-corporation rate and base: § 71.365(4m)(a), (d)1."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
              "cell_locator": "WI.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "Election requires consent from holders of more than 50% of partnership capital and profits or more than 50% of corporation shares."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
              "cell_locator": "WI.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "Each current statutory election applies for the taxable year identified on the entity's timely or timely extended return."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
              "cell_locator": "WI.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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)."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
              "cell_locator": "WI.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "An eligible partnership or federal S corporation may elect annual entity-level tax at 7.9% of Wisconsin-reportable net income."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
              "cell_locator": "WI.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "No holding-entity or passive-income carve-out was located in either election subsection; the regime is elective."
            }
          },
          "jurisdiction": "WI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://docs.legis.wisconsin.gov/document/statutes/71.21",
          "state": "Wisconsin"
        },
        {
          "cells": {
            "base_tax_locator.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-21-3a/",
              "cell_locator": "WV.llc.base_tax_locator.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pass_through_entity_tax",
              "value": "The elective entity-level tax's base and rate cross-reference are located in W. Va. Code §11-21-3a(k)."
            },
            "does_not_reach.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-21-3a/",
              "cell_locator": "WV.llc.does_not_reach.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pass_through_entity_tax",
              "value": "The election is unavailable to a federally disregarded entity, and the pass-through entity definition excludes an entity subject to Article 24 corporation tax."
            },
            "effective_period.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-21-3a/",
              "cell_locator": "WV.llc.effective_period.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pass_through_entity_tax",
              "value": "The entity-level election is available for taxable years beginning on and after January 1, 2022."
            },
            "filing_rule.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-21-3a/",
              "cell_locator": "WV.llc.filing_rule.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-21-3a/",
              "cell_locator": "WV.llc.tax_regime.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pass_through_entity_tax",
              "value": "West Virginia annually imposes tax at the top individual marginal rate on the West Virginia taxable income of an electing pass-through entity."
            },
            "treatment.elective_pass_through_entity_tax": {
              "cell_citation_url": "https://code.wvlegislature.gov/11-21-3a/",
              "cell_locator": "WV.llc.treatment.elective_pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "WV",
          "last_checked": "2026-10-03",
          "official_source_url": "https://code.wvlegislature.gov/11-21-3a/",
          "state": "West Virginia"
        }
      ],
      "scope_label": "23 jurisdictions"
    },
    "state-tax-37": {
      "field_definitions": {
        "base_tax_locator.elective_pte_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.elective_pte_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.elective_pte_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.elective_pte_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.elective_pte_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.elective_pte_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-06",
      "matrix_id": "pp-holding-entity-tax:state-tax-37",
      "rows": [
        {
          "cells": {
            "base_tax_locator.elective_pte_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm",
              "cell_locator": "MS.llc.base_tax_locator.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pte_tax",
              "value": "The election and entity-level payment rule are in §27-7-26, which applies the tax imposed under chapter 7; no amount is transcribed here."
            },
            "does_not_reach.elective_pte_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/sites/default/files/notices-technical-bulletins/Pass-Through%2520Entity%2520Revised%2520Election%2520Notice%25204-13-23.pdf",
              "cell_locator": "MS.llc.does_not_reach.elective_pte_tax",
              "note": "The official record does not state this",
              "publish_status": "typed_unknown",
              "source_field": "does_not_reach.elective_pte_tax",
              "value": "official_record_silent",
              "visible_subline": "Filing an Electing Pass-Through Entity Return\nAn electing PTE will file the Pass-Through Entity Tax Return, form 84-105, and check the “Electing Pass-Through\nEntity” check box in order to be taxed at the entity level. A copy of the Pass-Through Entity Election Form, form\n84-381, should also be attached to the return."
            },
            "effective_period.elective_pte_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm",
              "cell_locator": "MS.llc.effective_period.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pte_tax",
              "value": "The elective entity-level regime applies for calendar year 2022 and each calendar year thereafter."
            },
            "filing_rule.elective_pte_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/sites/default/files/business/Updated%20EPTE%20FAQ.pdf",
              "cell_locator": "MS.llc.filing_rule.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pte_tax",
              "value": "An electing PTE files Form 84-105, checks the electing-PTE box, and attaches Form 84-381."
            },
            "tax_regime.elective_pte_tax": {
              "cell_citation_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm",
              "cell_locator": "MS.llc.tax_regime.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pte_tax",
              "value": "A partnership, S corporation, or similar pass-through entity may elect to pay Mississippi income tax at the entity level."
            },
            "treatment.elective_pte_tax": {
              "cell_citation_url": "https://www.dor.ms.gov/sites/default/files/notices-technical-bulletins/Pass-Through%2520Entity%2520Revised%2520Election%2520Notice%25204-13-23.pdf",
              "cell_locator": "MS.llc.treatment.elective_pte_tax",
              "note": "The official record does not state this",
              "publish_status": "typed_unknown",
              "source_field": "treatment.elective_pte_tax",
              "value": "official_record_silent",
              "visible_subline": "Filing an Electing Pass-Through Entity Return\nAn electing PTE will file the Pass-Through Entity Tax Return, form 84-105, and check the “Electing Pass-Through\nEntity” check box in order to be taxed at the entity level. A copy of the Pass-Through Entity Election Form, form\n84-381, should also be attached to the return."
            }
          },
          "jurisdiction": "MS",
          "last_checked": "2026-10-06",
          "official_source_url": "https://billstatus.ls.state.ms.us/documents/2023/html/HB/1600-1699/HB1668SG.htm",
          "state": "Mississippi"
        },
        {
          "cells": {
            "base_tax_locator.elective_pte_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.3_44-11-2.3.htm",
              "cell_locator": "RI.llc.base_tax_locator.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.elective_pte_tax",
              "value": "The elective PTE tax base and rate are located in §44-11-2.3(a)(2) and (b)(1); no amount is transcribed here."
            },
            "does_not_reach.elective_pte_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.3_44-11-2.3.htm",
              "cell_locator": "RI.llc.does_not_reach.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.elective_pte_tax",
              "value": "The elective PTE tax base does not include specially allocated investment income under §44-11-2.3(a)(2)."
            },
            "effective_period.elective_pte_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.3_44-11-2.3.htm",
              "cell_locator": "RI.llc.effective_period.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.elective_pte_tax",
              "value": "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."
            },
            "filing_rule.elective_pte_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.3_44-11-2.3.htm",
              "cell_locator": "RI.llc.filing_rule.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.elective_pte_tax",
              "value": "The annual election is made by filing the prescribed tax form and remitting the appropriate tax (§44-11-2.3(a)(1))."
            },
            "tax_regime.elective_pte_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.3_44-11-2.3.htm",
              "cell_locator": "RI.llc.tax_regime.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.elective_pte_tax",
              "value": "A qualifying pass-through entity may elect to pay Rhode Island tax at the entity level (§44-11-2.3(b)(1))."
            },
            "treatment.elective_pte_tax": {
              "cell_citation_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.3_44-11-2.3.htm",
              "cell_locator": "RI.llc.treatment.elective_pte_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.elective_pte_tax",
              "value": "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."
            }
          },
          "jurisdiction": "RI",
          "last_checked": "2026-10-02",
          "official_source_url": "https://webserver.rilegislature.gov/Statutes/TITLE44/44-11/44-11-2.3_44-11-2.3.htm",
          "state": "Rhode Island"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-38": {
      "field_definitions": {
        "base_tax_locator.excise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.excise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.excise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.excise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.excise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.excise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-38",
      "rows": [
        {
          "cells": {
            "base_tax_locator.excise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.base_tax_locator.excise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.excise_tax",
              "value": "Base and rate: Tenn. Code Ann. § 67-4-2006 (net earnings, Schedule J adjustments, including deductions for dividends from 80%-owned corporations and taxed pass-through income) and § 67-4-2007; no amounts reproduced."
            },
            "does_not_reach.excise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.does_not_reach.excise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.excise_tax",
              "value": "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."
            },
            "effective_period.excise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.effective_period.excise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.excise_tax",
              "value": "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."
            },
            "filing_rule.excise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.filing_rule.excise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.excise_tax",
              "value": "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."
            },
            "tax_regime.excise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.tax_regime.excise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.excise_tax",
              "value": "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."
            },
            "treatment.excise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.treatment.excise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.excise_tax",
              "value": "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."
            }
          },
          "jurisdiction": "TN",
          "last_checked": "2026-10-02",
          "official_source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
          "state": "Tennessee"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-39": {
      "field_definitions": {
        "base_tax_locator.flow_through_entity_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.flow_through_entity_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.flow_through_entity_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.flow_through_entity_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.flow_through_entity_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.flow_through_entity_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-39",
      "rows": [
        {
          "cells": {
            "base_tax_locator.flow_through_entity_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.base_tax_locator.flow_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.flow_through_entity_tax",
              "value": "The FTE tax base, adjustments and member-allocation rule are located in MCL 206.815; MCL 206.817 governs apportionment."
            },
            "does_not_reach.flow_through_entity_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.does_not_reach.flow_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.flow_through_entity_tax",
              "value": "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."
            },
            "effective_period.flow_through_entity_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.effective_period.flow_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.flow_through_entity_tax",
              "value": "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."
            },
            "filing_rule.flow_through_entity_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.filing_rule.flow_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.flow_through_entity_tax",
              "value": "An annual or final FTE return is due by the last day of the third month after the taxpayer's tax year ends."
            },
            "tax_regime.flow_through_entity_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.tax_regime.flow_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.flow_through_entity_tax",
              "value": "Subject to MCL 206.847, Michigan levies Flow-Through Entity Tax on every electing taxpayer with Michigan business activity."
            },
            "treatment.flow_through_entity_tax": {
              "cell_citation_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
              "cell_locator": "MI.llc.treatment.flow_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.flow_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "MI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.legislature.mi.gov/documents/mcl/pdf/MCL-ACT-281-OF-1967.pdf",
          "state": "Michigan"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-40": {
      "field_definitions": {
        "base_tax_locator.franchise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.franchise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.franchise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.franchise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.franchise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.franchise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-40",
      "rows": [
        {
          "cells": {
            "base_tax_locator.franchise_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
              "cell_locator": "NC.llc.base_tax_locator.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.franchise_tax",
              "value": "Holding-company base and rate: § 105-120.2(a)-(b); general corporate net-worth base: § 105-122(b)."
            },
            "does_not_reach.franchise_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
              "cell_locator": "NC.llc.does_not_reach.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.franchise_tax",
              "value": "The general § 105-122 franchise tax does not apply to a business taxed under the holding-company provision, § 105-120.2."
            },
            "effective_period.franchise_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
              "cell_locator": "NC.llc.effective_period.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.franchise_tax",
              "value": "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."
            },
            "filing_rule.franchise_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
              "cell_locator": "NC.llc.filing_rule.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.franchise_tax",
              "value": "A corporation meeting the holding-company test must file a return, determine total net worth, and apportion that net worth to North Carolina."
            },
            "tax_regime.franchise_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-122.html",
              "cell_locator": "NC.llc.tax_regime.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.franchise_tax",
              "value": "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."
            },
            "treatment.franchise_tax": {
              "cell_citation_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-120.2.html",
              "cell_locator": "NC.llc.treatment.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.franchise_tax",
              "value": "A qualifying holding company pays under § 105-120.2's special base limits and is not also taxed under the general § 105-122 rule."
            }
          },
          "jurisdiction": "NC",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_105/GS_105-122.html",
          "state": "North Carolina"
        },
        {
          "cells": {
            "base_tax_locator.franchise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.base_tax_locator.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.franchise_tax",
              "value": "Base and rate: Tenn. Code Ann. §§ 67-4-2106 and 67-4-2107 (net worth, Schedules F1/F2) and § 67-4-2119 (minimum tax); amounts are not reproduced here."
            },
            "does_not_reach.franchise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.does_not_reach.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.franchise_tax",
              "value": "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."
            },
            "effective_period.franchise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.effective_period.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.franchise_tax",
              "value": "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."
            },
            "filing_rule.franchise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.filing_rule.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.franchise_tax",
              "value": "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."
            },
            "tax_regime.franchise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.tax_regime.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.franchise_tax",
              "value": "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."
            },
            "treatment.franchise_tax": {
              "cell_citation_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
              "cell_locator": "TN.llc.treatment.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.franchise_tax",
              "value": "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."
            }
          },
          "jurisdiction": "TN",
          "last_checked": "2026-10-02",
          "official_source_url": "https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/june-2026/franchise-tax.pdf",
          "state": "Tennessee"
        },
        {
          "cells": {
            "base_tax_locator.franchise_tax": {
              "cell_citation_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
              "cell_locator": "TX.llc.base_tax_locator.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.franchise_tax",
              "value": "Rate and computation: Tax Code § 171.002 (threshold adjusted under § 171.006); taxable margin § 171.101; total revenue § 171.1011; E-Z computation § 171.1016; apportionment § 171.106."
            },
            "does_not_reach.franchise_tax": {
              "cell_citation_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
              "cell_locator": "TX.llc.does_not_reach.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.franchise_tax",
              "value": "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."
            },
            "effective_period.franchise_tax": {
              "cell_citation_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
              "cell_locator": "TX.llc.effective_period.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.franchise_tax",
              "value": "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."
            },
            "filing_rule.franchise_tax": {
              "cell_citation_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
              "cell_locator": "TX.llc.filing_rule.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.franchise_tax",
              "value": "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."
            },
            "tax_regime.franchise_tax": {
              "cell_citation_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
              "cell_locator": "TX.llc.tax_regime.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.franchise_tax",
              "value": "Franchise tax under Tax Code chapter 171, imposed on each taxable entity that does business in Texas or is chartered or organized in Texas."
            },
            "treatment.franchise_tax": {
              "cell_citation_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
              "cell_locator": "TX.llc.treatment.franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.franchise_tax",
              "value": "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."
            }
          },
          "jurisdiction": "TX",
          "last_checked": "2026-10-02",
          "official_source_url": "https://tcss.legis.texas.gov/resources/TX/htm/TX.171.htm",
          "state": "Texas"
        }
      ],
      "scope_label": "3 jurisdictions"
    },
    "state-tax-41": {
      "field_definitions": {
        "base_tax_locator.general_excise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.general_excise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.general_excise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.general_excise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.general_excise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.general_excise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-41",
      "rows": [
        {
          "cells": {
            "base_tax_locator.general_excise_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
              "cell_locator": "HI.llc.base_tax_locator.general_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.general_excise_tax",
              "value": "The other-business gross-income base and rate are located in §237-13(9), with gross income defined in §237-3; no amount is transcribed here."
            },
            "does_not_reach.general_excise_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
              "cell_locator": "HI.llc.does_not_reach.general_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.general_excise_tax",
              "value": "The gross-income definition excludes specified securities-sale and indebtedness receipts and dividends; §237-23.5 separately exempts qualifying related-entity interest."
            },
            "effective_period.general_excise_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
              "cell_locator": "HI.llc.effective_period.general_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.general_excise_tax",
              "value": "No current effective or sunset period for the general excise tax was stated in the complete chapter 237 capture."
            },
            "filing_rule.general_excise_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
              "cell_locator": "HI.llc.filing_rule.general_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.general_excise_tax",
              "value": "Each taxpayer files an annual return by the twentieth day of the fourth month after the taxable year closes."
            },
            "tax_regime.general_excise_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
              "cell_locator": "HI.llc.tax_regime.general_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.general_excise_tax",
              "value": "Hawaii imposes general excise tax on gross income from a business or activity not otherwise taxed under chapter 237."
            },
            "treatment.general_excise_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
              "cell_locator": "HI.llc.treatment.general_excise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.general_excise_tax",
              "value": "Gross income includes receipts from invested business capital, including interest and royalties; specified securities-sale receipts and dividends are excluded."
            }
          },
          "jurisdiction": "HI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_237.pdf",
          "state": "Hawaii"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-42": {
      "field_definitions": {
        "base_tax_locator.gross_receipts_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.gross_receipts_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.gross_receipts_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.gross_receipts_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.gross_receipts_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.gross_receipts_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-42",
      "rows": [
        {
          "cells": {
            "base_tax_locator.gross_receipts_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.base_tax_locator.gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.gross_receipts_tax",
              "value": "The state gross-receipts-tax rate is located at NMSA 1978, § 7-9-4(A)."
            },
            "does_not_reach.gross_receipts_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.does_not_reach.gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.gross_receipts_tax",
              "value": "The exemption is receipt-specific: interest on money loaned or deposited, dividends or interest from securities, and proceeds from securities sales."
            },
            "effective_period.gross_receipts_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.effective_period.gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.gross_receipts_tax",
              "value": "The dividends, interest, and securities-sale exemption has been effective since July 1, 1969."
            },
            "filing_rule.gross_receipts_tax": {
              "cell_citation_url": "https://www.tax.newmexico.gov/businesses/gross-receipts-overview/",
              "cell_locator": "NM.llc.filing_rule.gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.gross_receipts_tax",
              "value": "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."
            },
            "tax_regime.gross_receipts_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.tax_regime.gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.gross_receipts_tax",
              "value": "Gross receipts tax is imposed on a person engaging in business in New Mexico, subject to the Act's exemptions and deductions."
            },
            "treatment.gross_receipts_tax": {
              "cell_citation_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
              "cell_locator": "NM.llc.treatment.gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.gross_receipts_tax",
              "value": "An LLC remains within the gross-receipts regime, but the listed interest, dividend, and securities-sale receipts are exempt."
            }
          },
          "jurisdiction": "NM",
          "last_checked": "2026-10-03",
          "official_source_url": "https://nmonesource.com/nmos/nmsa/en/4340/1/document.do",
          "state": "New Mexico"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-43": {
      "field_definitions": {
        "base_tax_locator.headquarters_management_corporation_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.headquarters_management_corporation_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.headquarters_management_corporation_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.headquarters_management_corporation_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.headquarters_management_corporation_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.headquarters_management_corporation_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-43",
      "rows": [
        {
          "cells": {
            "base_tax_locator.headquarters_management_corporation_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c064/index.html",
              "cell_locator": "DE.llc.base_tax_locator.headquarters_management_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.headquarters_management_corporation_tax",
              "value": "The tax is set in 30 Del. C. § 6402 and its base computed under § 6403; the separate Headquarters Management Corporation license tax is in § 2301(a)(25), with § 2301(f)."
            },
            "does_not_reach.headquarters_management_corporation_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c064/index.html",
              "cell_locator": "DE.llc.does_not_reach.headquarters_management_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.headquarters_management_corporation_tax",
              "value": "The election ends if the taxpayer revokes it or fails to limit its Delaware activities to headquarters services or investment activities."
            },
            "effective_period.headquarters_management_corporation_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c064/index.html",
              "cell_locator": "DE.llc.effective_period.headquarters_management_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.headquarters_management_corporation_tax",
              "value": "Chapter 64 states no effective or sunset date for the Headquarters Management Corporation tax; a full-text search of the chapter found none."
            },
            "filing_rule.headquarters_management_corporation_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c064/index.html",
              "cell_locator": "DE.llc.filing_rule.headquarters_management_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.headquarters_management_corporation_tax",
              "value": "The election is filed with the Headquarters Management Corporation license application, and annual tentative and final returns are required regardless of liability or income."
            },
            "tax_regime.headquarters_management_corporation_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c064/index.html",
              "cell_locator": "DE.llc.tax_regime.headquarters_management_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.headquarters_management_corporation_tax",
              "value": "A certified Headquarters Management Corporation pays an annual tax in lieu of the Chapter 19 corporation income tax (30 Del. C. § 6402)."
            },
            "treatment.headquarters_management_corporation_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c064/index.html",
              "cell_locator": "DE.llc.treatment.headquarters_management_corporation_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.headquarters_management_corporation_tax",
              "value": "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)."
            }
          },
          "jurisdiction": "DE",
          "last_checked": "2026-10-02",
          "official_source_url": "https://delcode.delaware.gov/title30/c064/index.html",
          "state": "Delaware"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-44": {
      "field_definitions": {
        "base_tax_locator.income_tax_on_banks_and_financial_corporations": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.income_tax_on_banks_and_financial_corporations": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.income_tax_on_banks_and_financial_corporations": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.income_tax_on_banks_and_financial_corporations": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.income_tax_on_banks_and_financial_corporations": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.income_tax_on_banks_and_financial_corporations": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-44",
      "rows": [
        {
          "cells": {
            "base_tax_locator.income_tax_on_banks_and_financial_corporations": {
              "cell_citation_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43",
              "cell_locator": "SD.llc.base_tax_locator.income_tax_on_banks_and_financial_corporations",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.income_tax_on_banks_and_financial_corporations",
              "value": "The chapter 10-43 rate and minimum are located in SDCL 10-43-4; net-income definition and adjustments are in SDCL 10-43-10.1 through 10-43-10.5."
            },
            "does_not_reach.income_tax_on_banks_and_financial_corporations": {
              "cell_citation_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43-1",
              "cell_locator": "SD.llc.does_not_reach.income_tax_on_banks_and_financial_corporations",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.income_tax_on_banks_and_financial_corporations",
              "value": "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."
            },
            "effective_period.income_tax_on_banks_and_financial_corporations": {
              "cell_citation_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43",
              "cell_locator": "SD.llc.effective_period.income_tax_on_banks_and_financial_corporations",
              "publish_status": "publish_ready",
              "source_field": "effective_period.income_tax_on_banks_and_financial_corporations",
              "value": "The complete current chapter states no operative effective or sunset date for the current holding-income rules or securitization exclusion."
            },
            "filing_rule.income_tax_on_banks_and_financial_corporations": {
              "cell_citation_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43",
              "cell_locator": "SD.llc.filing_rule.income_tax_on_banks_and_financial_corporations",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.income_tax_on_banks_and_financial_corporations",
              "value": "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."
            },
            "tax_regime.income_tax_on_banks_and_financial_corporations": {
              "cell_citation_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43-2",
              "cell_locator": "SD.llc.tax_regime.income_tax_on_banks_and_financial_corporations",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.income_tax_on_banks_and_financial_corporations",
              "value": "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."
            },
            "treatment.income_tax_on_banks_and_financial_corporations": {
              "cell_citation_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43",
              "cell_locator": "SD.llc.treatment.income_tax_on_banks_and_financial_corporations",
              "publish_status": "publish_ready",
              "source_field": "treatment.income_tax_on_banks_and_financial_corporations",
              "value": "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."
            }
          },
          "jurisdiction": "SD",
          "last_checked": "2026-10-03",
          "official_source_url": "https://sdlegislature.gov/api/Statutes/Statute/10-43-2",
          "state": "South Dakota"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-45": {
      "field_definitions": {
        "base_tax_locator.limited_liability_entity_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.limited_liability_entity_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.limited_liability_entity_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.limited_liability_entity_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.limited_liability_entity_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.limited_liability_entity_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-45",
      "rows": [
        {
          "cells": {
            "base_tax_locator.limited_liability_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57941",
              "cell_locator": "KY.llc.base_tax_locator.limited_liability_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.limited_liability_entity_tax",
              "value": "The LLET base and rate are located at KRS 141.0401(2)."
            },
            "does_not_reach.limited_liability_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942",
              "cell_locator": "KY.llc.does_not_reach.limited_liability_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.limited_liability_entity_tax",
              "value": "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."
            },
            "effective_period.limited_liability_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942",
              "cell_locator": "KY.llc.effective_period.limited_liability_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.limited_liability_entity_tax",
              "value": "The current qualified-investment-partnership provision in KRS 141.206 is effective July 15, 2026."
            },
            "filing_rule.limited_liability_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942",
              "cell_locator": "KY.llc.filing_rule.limited_liability_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.limited_liability_entity_tax",
              "value": "A qualified investment partnership remains subject to the other PTE provisions, including the annual federal-return-copy filing rule in KRS 141.206(1)."
            },
            "tax_regime.limited_liability_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57941",
              "cell_locator": "KY.llc.tax_regime.limited_liability_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.limited_liability_entity_tax",
              "value": "Kentucky imposes annual LLET on every corporation and limited liability pass-through entity doing business in Kentucky, subject to stated exceptions."
            },
            "treatment.limited_liability_entity_tax": {
              "cell_citation_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57942",
              "cell_locator": "KY.llc.treatment.limited_liability_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.limited_liability_entity_tax",
              "value": "A holding LLC that meets the qualified-investment-partnership test is expressly not subject to LLET under KRS 141.206(14)(b)."
            }
          },
          "jurisdiction": "KY",
          "last_checked": "2026-10-02",
          "official_source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=57941",
          "state": "Kentucky"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-46": {
      "field_definitions": {
        "base_tax_locator.llc_annual_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.llc_annual_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.llc_annual_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.llc_annual_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.llc_annual_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.llc_annual_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-46",
      "rows": [
        {
          "cells": {
            "base_tax_locator.llc_annual_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.base_tax_locator.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.llc_annual_tax",
              "value": "The amount is set by reference to R&TC § 23153(d) under § 17941(a); § 17941(g) states first-taxable-year rules."
            },
            "does_not_reach.llc_annual_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.does_not_reach.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.llc_annual_tax",
              "value": "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."
            },
            "effective_period.llc_annual_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.effective_period.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.llc_annual_tax",
              "value": "The annual tax applies to taxable years beginning on or after January 1, 1997; § 17941 was last amended effective July 13, 2026."
            },
            "filing_rule.llc_annual_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.&article=",
              "cell_locator": "CA.llc.filing_rule.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.llc_annual_tax",
              "value": "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."
            },
            "tax_regime.llc_annual_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.tax_regime.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.llc_annual_tax",
              "value": "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."
            },
            "treatment.llc_annual_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.treatment.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.llc_annual_tax",
              "value": "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."
            }
          },
          "jurisdiction": "CA",
          "last_checked": "2026-10-02",
          "official_source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
          "state": "California"
        },
        {
          "cells": {
            "base_tax_locator.llc_annual_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
              "cell_locator": "DE.llc.base_tax_locator.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.llc_annual_tax",
              "value": "The annual tax amounts are set in 6 Del. C. § 18-1107(b), with the due date and interest in § 18-1107(c) and the late-payment penalty in § 18-1107(e)."
            },
            "does_not_reach.llc_annual_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
              "cell_locator": "DE.llc.does_not_reach.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.llc_annual_tax",
              "value": "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."
            },
            "effective_period.llc_annual_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
              "cell_locator": "DE.llc.effective_period.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.llc_annual_tax",
              "value": "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."
            },
            "filing_rule.llc_annual_tax": {
              "cell_citation_url": "https://corp.delaware.gov/alt-entitytaxinstructions/",
              "cell_locator": "DE.llc.filing_rule.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.llc_annual_tax",
              "value": "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."
            },
            "tax_regime.llc_annual_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
              "cell_locator": "DE.llc.tax_regime.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.llc_annual_tax",
              "value": "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)."
            },
            "treatment.llc_annual_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
              "cell_locator": "DE.llc.treatment.llc_annual_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.llc_annual_tax",
              "value": "The annual tax reaches every domestic LLC and every registered foreign LLC; the LLC Act states no exception for holding or passive LLCs."
            }
          },
          "jurisdiction": "DE",
          "last_checked": "2026-10-02",
          "official_source_url": "https://delcode.delaware.gov/title6/c018/sc11/index.html",
          "state": "Delaware"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-47": {
      "field_definitions": {
        "base_tax_locator.llc_fee": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.llc_fee": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.llc_fee": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.llc_fee": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.llc_fee": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.llc_fee": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-47",
      "rows": [
        {
          "cells": {
            "base_tax_locator.llc_fee": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.base_tax_locator.llc_fee",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.llc_fee",
              "value": "Fee tiers are in R&TC § 17942(a)(1)-(4); the income measure and its assignment to California are in § 17942(b)."
            },
            "does_not_reach.llc_fee": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.does_not_reach.llc_fee",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.llc_fee",
              "value": "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."
            },
            "effective_period.llc_fee": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.effective_period.llc_fee",
              "publish_status": "publish_ready",
              "source_field": "effective_period.llc_fee",
              "value": "§ 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."
            },
            "filing_rule.llc_fee": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.filing_rule.llc_fee",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.llc_fee",
              "value": "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."
            },
            "tax_regime.llc_fee": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.tax_regime.llc_fee",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.llc_fee",
              "value": "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))."
            },
            "treatment.llc_fee": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
              "cell_locator": "CA.llc.treatment.llc_fee",
              "publish_status": "publish_ready",
              "source_field": "treatment.llc_fee",
              "value": "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."
            }
          },
          "jurisdiction": "CA",
          "last_checked": "2026-10-02",
          "official_source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.&chapter=10.6.&article=",
          "state": "California"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-48": {
      "field_definitions": {
        "base_tax_locator.minimum_fee": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.minimum_fee": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.minimum_fee": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.minimum_fee": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.minimum_fee": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.minimum_fee": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-48",
      "rows": [
        {
          "cells": {
            "base_tax_locator.minimum_fee": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.base_tax_locator.minimum_fee",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.minimum_fee",
              "value": "The filing-entity imposition, factor thresholds, and factor definitions are located in §290.0922, subds. 1 and 3; no amount is transcribed here."
            },
            "does_not_reach.minimum_fee": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.does_not_reach.minimum_fee",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.minimum_fee",
              "value": "The fee does not reach the expressly exempt entities, including REITs, regulated investment companies or their funds, and §860D(b)-electing entities."
            },
            "effective_period.minimum_fee": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.effective_period.minimum_fee",
              "publish_status": "publish_ready",
              "source_field": "effective_period.minimum_fee",
              "value": "No current sunset or effective period for the minimum fee was stated in the complete chapter 290 capture."
            },
            "filing_rule.minimum_fee": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.filing_rule.minimum_fee",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.minimum_fee",
              "value": "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)."
            },
            "tax_regime.minimum_fee": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.tax_regime.minimum_fee",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.minimum_fee",
              "value": "Minnesota imposes the minimum fee on filing S corporations and partnerships, with a separate included fee for filing C corporations."
            },
            "treatment.minimum_fee": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.treatment.minimum_fee",
              "publish_status": "publish_ready",
              "source_field": "treatment.minimum_fee",
              "value": "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."
            }
          },
          "jurisdiction": "MN",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
          "state": "Minnesota"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-49": {
      "field_definitions": {
        "base_tax_locator.nonresident_partner_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.nonresident_partner_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.nonresident_partner_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.nonresident_partner_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.nonresident_partner_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.nonresident_partner_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-49",
      "rows": [
        {
          "cells": {
            "base_tax_locator.nonresident_partner_tax": {
              "cell_citation_url": "https://pub.njleg.state.nj.us/Bills/2022/PL22/133_.PDF",
              "cell_locator": "NJ.llc.base_tax_locator.nonresident_partner_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.nonresident_partner_tax",
              "value": "The nonresident-partner payment computation is located at N.J.S.A. 54:10A-15.11(a)(1)."
            },
            "does_not_reach.nonresident_partner_tax": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/cbt1065i.pdf",
              "cell_locator": "NJ.llc.does_not_reach.nonresident_partner_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.nonresident_partner_tax",
              "value": "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."
            },
            "effective_period.nonresident_partner_tax": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/cbt1065i.pdf",
              "cell_locator": "NJ.llc.effective_period.nonresident_partner_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.nonresident_partner_tax",
              "value": "The cited partnership instructions apply to calendar year 2025 and fiscal years beginning in 2025."
            },
            "filing_rule.nonresident_partner_tax": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/cbt1065i.pdf",
              "cell_locator": "NJ.llc.filing_rule.nonresident_partner_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.nonresident_partner_tax",
              "value": "Form NJ-CBT-1065 must be filed when the entity must calculate tax on nonresident partners."
            },
            "tax_regime.nonresident_partner_tax": {
              "cell_citation_url": "https://pub.njleg.state.nj.us/Bills/2022/PL22/133_.PDF",
              "cell_locator": "NJ.llc.tax_regime.nonresident_partner_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.nonresident_partner_tax",
              "value": "A partnership outside the listed exclusions must remit tax on allocated entire net income shares of nonresident partners."
            },
            "treatment.nonresident_partner_tax": {
              "cell_citation_url": "https://pub.njleg.state.nj.us/Bills/2022/PL22/133_.PDF",
              "cell_locator": "NJ.llc.treatment.nonresident_partner_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.nonresident_partner_tax",
              "value": "N.J.S.A. 54:10A-15.11 excludes qualified investment partnerships and investment clubs from the partnership payment rule."
            }
          },
          "jurisdiction": "NJ",
          "last_checked": "2026-10-03",
          "official_source_url": "https://pub.njleg.state.nj.us/Bills/2022/PL22/133_.PDF",
          "state": "New Jersey"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-50": {
      "field_definitions": {
        "base_tax_locator.occupational_license_gross_receipts_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.occupational_license_gross_receipts_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.occupational_license_gross_receipts_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.occupational_license_gross_receipts_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.occupational_license_gross_receipts_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.occupational_license_gross_receipts_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-50",
      "rows": [
        {
          "cells": {
            "base_tax_locator.occupational_license_gross_receipts_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c023/index.html",
              "cell_locator": "DE.llc.base_tax_locator.occupational_license_gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.occupational_license_gross_receipts_tax",
              "value": "License tax amounts are in 30 Del. C. § 2301(a) and (b); the gross receipts license fee rate and its deductions are in § 2301(d)."
            },
            "does_not_reach.occupational_license_gross_receipts_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c023/index.html",
              "cell_locator": "DE.llc.does_not_reach.occupational_license_gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.occupational_license_gross_receipts_tax",
              "value": "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."
            },
            "effective_period.occupational_license_gross_receipts_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c023/index.html",
              "cell_locator": "DE.llc.effective_period.occupational_license_gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.occupational_license_gross_receipts_tax",
              "value": "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."
            },
            "filing_rule.occupational_license_gross_receipts_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c023/index.html",
              "cell_locator": "DE.llc.filing_rule.occupational_license_gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.occupational_license_gross_receipts_tax",
              "value": "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."
            },
            "tax_regime.occupational_license_gross_receipts_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c023/index.html",
              "cell_locator": "DE.llc.tax_regime.occupational_license_gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.occupational_license_gross_receipts_tax",
              "value": "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."
            },
            "treatment.occupational_license_gross_receipts_tax": {
              "cell_citation_url": "https://delcode.delaware.gov/title30/c023/index.html",
              "cell_locator": "DE.llc.treatment.occupational_license_gross_receipts_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.occupational_license_gross_receipts_tax",
              "value": "§ 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."
            }
          },
          "jurisdiction": "DE",
          "last_checked": "2026-10-02",
          "official_source_url": "https://delcode.delaware.gov/title30/c023/index.html",
          "state": "Delaware"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-51": {
      "field_definitions": {
        "base_tax_locator.partnership_filing_fee": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.partnership_filing_fee": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.partnership_filing_fee": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.partnership_filing_fee": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.partnership_filing_fee": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.partnership_filing_fee": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-51",
      "rows": [
        {
          "cells": {
            "base_tax_locator.partnership_filing_fee": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
              "cell_locator": "NJ.llc.base_tax_locator.partnership_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.partnership_filing_fee",
              "value": "The fee is located at N.J.S.A. 54A:8-6(b)(2)(A) and the Partnership Filing Fee schedule in Form NJ-1065."
            },
            "does_not_reach.partnership_filing_fee": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
              "cell_locator": "NJ.llc.does_not_reach.partnership_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.partnership_filing_fee",
              "value": "The current instructions exclude qualifying investment clubs; the general fee rule also requires New Jersey-source income or loss and more than two owners."
            },
            "effective_period.partnership_filing_fee": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
              "cell_locator": "NJ.llc.effective_period.partnership_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "effective_period.partnership_filing_fee",
              "value": "The cited instructions apply to calendar year 2025 and fiscal years beginning in 2025."
            },
            "filing_rule.partnership_filing_fee": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
              "cell_locator": "NJ.llc.filing_rule.partnership_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.partnership_filing_fee",
              "value": "A partnership with New Jersey-source income or loss, or any New Jersey resident partner, must file Form NJ-1065."
            },
            "tax_regime.partnership_filing_fee": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
              "cell_locator": "NJ.llc.tax_regime.partnership_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.partnership_filing_fee",
              "value": "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."
            },
            "treatment.partnership_filing_fee": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
              "cell_locator": "NJ.llc.treatment.partnership_filing_fee",
              "publish_status": "publish_ready",
              "source_field": "treatment.partnership_filing_fee",
              "value": "An investment club meeting the current stated test is exempt from the annual partnership filing fee."
            }
          },
          "jurisdiction": "NJ",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.nj.gov/treasury/taxation/pdf/current/part/1065i.pdf",
          "state": "New Jersey"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-52": {
      "field_definitions": {
        "base_tax_locator.partnership_llc_minimum_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.partnership_llc_minimum_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.partnership_llc_minimum_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.partnership_llc_minimum_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.partnership_llc_minimum_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.partnership_llc_minimum_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-52",
      "rows": [
        {
          "cells": {
            "base_tax_locator.partnership_llc_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.base_tax_locator.partnership_llc_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.partnership_llc_minimum_tax",
              "value": "The partnership and LLC minimum tax is located at 32 V.S.A. § 5921."
            },
            "does_not_reach.partnership_llc_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.does_not_reach.partnership_llc_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.partnership_llc_minimum_tax",
              "value": "The tax does not reach a qualifying investment club whose activities and both financial ceilings satisfy section 5921."
            },
            "effective_period.partnership_llc_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.effective_period.partnership_llc_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.partnership_llc_minimum_tax",
              "value": "The current minimum-tax section reflects an amendment effective April 29, 1998."
            },
            "filing_rule.partnership_llc_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.filing_rule.partnership_llc_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.partnership_llc_minimum_tax",
              "value": "A partnership or LLC within section 5920 must file an annual return by its federal-return due date."
            },
            "tax_regime.partnership_llc_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.tax_regime.partnership_llc_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.partnership_llc_minimum_tax",
              "value": "A partnership-classified LLC subject to section 5920 must pay the annual minimum tax."
            },
            "treatment.partnership_llc_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.treatment.partnership_llc_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.partnership_llc_minimum_tax",
              "value": "A qualifying investment club is exempt from the annual entity tax; the current BI-471 instructions operationalize the same two ceilings."
            }
          },
          "jurisdiction": "VT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
          "state": "Vermont"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-53": {
      "field_definitions": {
        "base_tax_locator.partnership_llc_nonresident_payment": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.partnership_llc_nonresident_payment": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.partnership_llc_nonresident_payment": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.partnership_llc_nonresident_payment": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.partnership_llc_nonresident_payment": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.partnership_llc_nonresident_payment": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-53",
      "rows": [
        {
          "cells": {
            "base_tax_locator.partnership_llc_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.base_tax_locator.partnership_llc_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.partnership_llc_nonresident_payment",
              "value": "The nonresident-partner or member payment formula is located at 32 V.S.A. § 5920(c)."
            },
            "does_not_reach.partnership_llc_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.does_not_reach.partnership_llc_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.partnership_llc_nonresident_payment",
              "value": "The complete current section 5920 states no holding- or passive-entity exclusion from subsection 5920(c)."
            },
            "effective_period.partnership_llc_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.effective_period.partnership_llc_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "effective_period.partnership_llc_nonresident_payment",
              "value": "The current mandatory-payment section reflects an amendment effective January 1, 2023."
            },
            "filing_rule.partnership_llc_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.filing_rule.partnership_llc_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.partnership_llc_nonresident_payment",
              "value": "Section 5920(a) still requires the partnership or LLC annual return by the federal-return due date."
            },
            "tax_regime.partnership_llc_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.tax_regime.partnership_llc_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.partnership_llc_nonresident_payment",
              "value": "A partnership or LLC is liable for Vermont income taxes imposed on nonresident partners or members with respect to entity income."
            },
            "treatment.partnership_llc_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.treatment.partnership_llc_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "treatment.partnership_llc_nonresident_payment",
              "value": "Section 5920(c) imposes the nonresident-member payment; the complete section states no holding- or passive-entity carveout."
            }
          },
          "jurisdiction": "VT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
          "state": "Vermont"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-54": {
      "field_definitions": {
        "base_tax_locator.pass_through_business_alternative_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.pass_through_business_alternative_income_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.pass_through_business_alternative_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.pass_through_business_alternative_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.pass_through_business_alternative_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.pass_through_business_alternative_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-54",
      "rows": [
        {
          "cells": {
            "base_tax_locator.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://pub.njleg.state.nj.us/Bills/2020/PL21/419_.HTM",
              "cell_locator": "NJ.llc.base_tax_locator.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.pass_through_business_alternative_income_tax",
              "value": "The PTE/BAIT base and rate table is located at N.J.S.A. 54A:12-3(b)(2)."
            },
            "does_not_reach.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://nj.gov/treasury/taxation/baitpte/index.shtml",
              "cell_locator": "NJ.llc.does_not_reach.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.pass_through_business_alternative_income_tax",
              "value": "The election requires at least one individual, estate, or trust member liable under the Gross Income Tax Act on distributive proceeds."
            },
            "effective_period.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://pub.njleg.state.nj.us/Bills/2020/PL21/419_.HTM",
              "cell_locator": "NJ.llc.effective_period.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.pass_through_business_alternative_income_tax",
              "value": "PTE/BAIT applies for taxable years beginning on or after January 1, 2020."
            },
            "filing_rule.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://www.nj.gov/treasury/taxation/pdf/current/pte-bait/pte100instr.pdf",
              "cell_locator": "NJ.llc.filing_rule.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.pass_through_business_alternative_income_tax",
              "value": "Every pass-through entity that made the election must file Form PTE-100."
            },
            "tax_regime.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://pub.njleg.state.nj.us/Bills/2020/PL21/419_.HTM",
              "cell_locator": "NJ.llc.tax_regime.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.pass_through_business_alternative_income_tax",
              "value": "An eligible pass-through entity may annually elect to pay PTE/BAIT at the entity level."
            },
            "treatment.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://pub.njleg.state.nj.us/Bills/2020/PL21/419_.HTM",
              "cell_locator": "NJ.llc.treatment.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.pass_through_business_alternative_income_tax",
              "value": "The complete current BAIT chapter states no separate holding- or passive-entity treatment."
            }
          },
          "jurisdiction": "NJ",
          "last_checked": "2026-10-03",
          "official_source_url": "https://pub.njleg.state.nj.us/Bills/2020/PL21/419_.HTM",
          "state": "New Jersey"
        },
        {
          "cells": {
            "base_tax_locator.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
              "cell_locator": "OR.llc.base_tax_locator.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.pass_through_business_alternative_income_tax",
              "value": "The elective regime's distributive-proceeds definition, tax base and rate are in sections 2(1) and 3(5)-(6), chapter 589, Oregon Laws 2021, as amended."
            },
            "does_not_reach.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
              "cell_locator": "OR.llc.does_not_reach.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.pass_through_business_alternative_income_tax",
              "value": "No holding or passive-entity carve-out was located, so the scoped provisions state no limits of such a carve-out."
            },
            "effective_period.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/lawsstatutes/2026orLaw0075.pdf",
              "cell_locator": "OR.llc.effective_period.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.pass_through_business_alternative_income_tax",
              "value": "The elective tax applies to tax years beginning on or after January 1, 2022, and before January 1, 2028."
            },
            "filing_rule.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
              "cell_locator": "OR.llc.filing_rule.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.pass_through_business_alternative_income_tax",
              "value": "An electing pass-through entity must file an entity tax return with payment by the chapter 316 return date provided in ORS 314.385."
            },
            "tax_regime.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
              "cell_locator": "OR.llc.tax_regime.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.pass_through_business_alternative_income_tax",
              "value": "An eligible pass-through entity may elect Oregon's Pass-Through Business Alternative Income Tax when its members satisfy the stated individual-ownership conditions."
            },
            "treatment.pass_through_business_alternative_income_tax": {
              "cell_citation_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
              "cell_locator": "OR.llc.treatment.pass_through_business_alternative_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.pass_through_business_alternative_income_tax",
              "value": "No holding carve-out was located; the elective tax base expressly uses distributive proceeds that include dividends, royalties, interest, rents and gains."
            }
          },
          "jurisdiction": "OR",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.oregonlegislature.gov/bills_laws/ors/ors314.html",
          "state": "Oregon"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-55": {
      "field_definitions": {
        "base_tax_locator.pass_through_entity_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.pass_through_entity_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.pass_through_entity_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.pass_through_entity_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.pass_through_entity_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.pass_through_entity_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-55",
      "rows": [
        {
          "cells": {
            "base_tax_locator.pass_through_entity_tax": {
              "cell_citation_url": "https://rules.sos.ga.gov/gac/560-7-3",
              "cell_locator": "GA.llc.base_tax_locator.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.pass_through_entity_tax",
              "value": "The elective PTE tax base is located in O.C.G.A. §§ 48-7-21 and 48-7-23 and Rule 560-7-3-.03(6)."
            },
            "does_not_reach.pass_through_entity_tax": {
              "cell_citation_url": "https://dor.georgia.gov/document/document/2025-it-711-partnership-income-tax-booklet/download",
              "cell_locator": "GA.llc.does_not_reach.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.pass_through_entity_tax",
              "value": "The securities exemption does not cover the stated family-controlled entities, participating managers, or owners in a unitary business with a participating manager."
            },
            "effective_period.pass_through_entity_tax": {
              "cell_citation_url": "https://rules.sos.ga.gov/gac/560-7-3",
              "cell_locator": "GA.llc.effective_period.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.pass_through_entity_tax",
              "value": "The PTE-election regulation applies to taxable years beginning on or after January 1, 2022."
            },
            "filing_rule.pass_through_entity_tax": {
              "cell_citation_url": "https://dor.georgia.gov/hb-149-pass-through-entity-tax-faq",
              "cell_locator": "GA.llc.filing_rule.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.pass_through_entity_tax": {
              "cell_citation_url": "https://dor.georgia.gov/taxes/taxes-partnerships",
              "cell_locator": "GA.llc.tax_regime.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.pass_through_entity_tax",
              "value": "When a qualifying partnership elects entity-level taxation, the partnership pays the income tax; this includes an LLC treated federally as a partnership."
            },
            "treatment.pass_through_entity_tax": {
              "cell_citation_url": "https://rules.sos.ga.gov/gac/560-7-3",
              "cell_locator": "GA.llc.treatment.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "GA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://dor.georgia.gov/taxes/taxes-partnerships",
          "state": "Georgia"
        },
        {
          "cells": {
            "base_tax_locator.pass_through_entity_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.base_tax_locator.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.pass_through_entity_tax",
              "value": "The entity-level PTE tax and rate are located at 35 ILCS 5/201(p)(2), and the net-income rules at paragraph (3)."
            },
            "does_not_reach.pass_through_entity_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.does_not_reach.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.pass_through_entity_tax",
              "value": "The election excludes publicly traded partnerships and years beginning in 2026 or later; the tiered subtraction requires an interest in another electing partnership."
            },
            "effective_period.pass_through_entity_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.effective_period.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.pass_through_entity_tax",
              "value": "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."
            },
            "filing_rule.pass_through_entity_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.filing_rule.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.pass_through_entity_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.tax_regime.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.pass_through_entity_tax",
              "value": "Within the stated taxable-year window, an electing partnership or S corporation is subject to Illinois PTE tax at the entity level."
            },
            "treatment.pass_through_entity_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.treatment.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.pass_through_entity_tax",
              "value": "An electing partnership that owns an interest in another electing partnership subtracts its distributive share of the lower-tier electing partnership's net income."
            }
          },
          "jurisdiction": "IL",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
          "state": "Illinois"
        },
        {
          "cells": {
            "base_tax_locator.pass_through_entity_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.base_tax_locator.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.pass_through_entity_tax",
              "value": "The PTE rate formulas and taxable-income or nonresident-taxable-income bases are located at § 10-102.1(d)."
            },
            "does_not_reach.pass_through_entity_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.does_not_reach.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.pass_through_entity_tax",
              "value": "The non-elective tax excludes specified shares of Maryland PTE, REIT, and Internal Revenue Code § 501 members."
            },
            "effective_period.pass_through_entity_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.effective_period.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.pass_through_entity_tax",
              "value": "The current PTE levy provision does not state an effective or sunset period; § 10-819.1 separately dates the future electronic-filing rule."
            },
            "filing_rule.pass_through_entity_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.filing_rule.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.pass_through_entity_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.tax_regime.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.pass_through_entity_tax",
              "value": "Each pass-through entity must pay the tax for nonresident-member shares or may elect to pay it for all member shares."
            },
            "treatment.pass_through_entity_tax": {
              "cell_citation_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
              "cell_locator": "MD.llc.treatment.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "MD",
          "last_checked": "2026-10-03",
          "official_source_url": "https://mgaleg.maryland.gov/2026RS/Statute_Web/gtg/gtg.pdf",
          "state": "Maryland"
        },
        {
          "cells": {
            "base_tax_locator.pass_through_entity_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
              "cell_locator": "WA.llc.base_tax_locator.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.pass_through_entity_tax",
              "value": "Rate and base sections: RCW 82A.04.520(1)(a) sets the rate on an electing entity's taxable income; RCW 82A.04.520(3) defines that taxable income."
            },
            "does_not_reach.pass_through_entity_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
              "cell_locator": "WA.llc.does_not_reach.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.pass_through_entity_tax",
              "value": "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."
            },
            "effective_period.pass_through_entity_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
              "cell_locator": "WA.llc.effective_period.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.pass_through_entity_tax",
              "value": "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."
            },
            "filing_rule.pass_through_entity_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
              "cell_locator": "WA.llc.filing_rule.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.pass_through_entity_tax",
              "value": "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."
            },
            "tax_regime.pass_through_entity_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
              "cell_locator": "WA.llc.tax_regime.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.pass_through_entity_tax",
              "value": "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."
            },
            "treatment.pass_through_entity_tax": {
              "cell_citation_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
              "cell_locator": "WA.llc.treatment.pass_through_entity_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.pass_through_entity_tax",
              "value": "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."
            }
          },
          "jurisdiction": "WA",
          "last_checked": "2026-10-02",
          "official_source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=82A.04&full=true",
          "state": "Washington"
        }
      ],
      "scope_label": "4 jurisdictions"
    },
    "state-tax-56": {
      "field_definitions": {
        "base_tax_locator.pass_through_entity_withholding_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.pass_through_entity_withholding_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.pass_through_entity_withholding_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.pass_through_entity_withholding_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.pass_through_entity_withholding_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.pass_through_entity_withholding_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-56",
      "rows": [
        {
          "cells": {
            "base_tax_locator.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.41",
              "cell_locator": "OH.llc.base_tax_locator.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.pass_through_entity_withholding_tax",
              "value": "The withholding tax's rate and base are set in R.C. 5747.41 (rate) and R.C. 5733.40 (adjusted qualifying amount); the return is R.C. 5747.42."
            },
            "does_not_reach.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5733.401",
              "cell_locator": "OH.llc.does_not_reach.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.pass_through_entity_withholding_tax",
              "value": "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."
            },
            "effective_period.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.41",
              "cell_locator": "OH.llc.effective_period.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.pass_through_entity_withholding_tax",
              "value": "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."
            },
            "filing_rule.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.41",
              "cell_locator": "OH.llc.filing_rule.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.pass_through_entity_withholding_tax",
              "value": "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."
            },
            "tax_regime.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.41",
              "cell_locator": "OH.llc.tax_regime.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.pass_through_entity_withholding_tax",
              "value": "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."
            },
            "treatment.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://codes.ohio.gov/ohio-revised-code/section-5733.401",
              "cell_locator": "OH.llc.treatment.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.pass_through_entity_withholding_tax",
              "value": "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."
            }
          },
          "jurisdiction": "OH",
          "last_checked": "2026-10-02",
          "official_source_url": "https://codes.ohio.gov/ohio-revised-code/section-5747.41",
          "state": "Ohio"
        },
        {
          "cells": {
            "base_tax_locator.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article16.1/",
              "cell_locator": "VA.llc.base_tax_locator.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.pass_through_entity_withholding_tax",
              "value": "The pass-through-entity withholding-tax base and rate are located at Va. Code § 58.1-486.2(B)(1)."
            },
            "does_not_reach.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://www.tax.virginia.gov/laws-rules-decisions/rulings-tax-commissioner/15-240",
              "cell_locator": "VA.llc.does_not_reach.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.pass_through_entity_withholding_tax",
              "value": "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."
            },
            "effective_period.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://www.tax.virginia.gov/laws-rules-decisions/rulings-tax-commissioner/15-240",
              "cell_locator": "VA.llc.effective_period.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.pass_through_entity_withholding_tax",
              "value": "The investment-PTE guidance applies to tax years beginning on or after January 1, 2015; statutory PTE withholding liability applies from January 1, 2008."
            },
            "filing_rule.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://www.tax.virginia.gov/laws-rules-decisions/rulings-tax-commissioner/15-240",
              "cell_locator": "VA.llc.filing_rule.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.pass_through_entity_withholding_tax",
              "value": "Public Document 15-240 states that a qualifying investment PTE need not pay the withholding tax or file Form 502."
            },
            "tax_regime.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article16.1/",
              "cell_locator": "VA.llc.tax_regime.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.pass_through_entity_withholding_tax",
              "value": "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."
            },
            "treatment.pass_through_entity_withholding_tax": {
              "cell_citation_url": "https://www.tax.virginia.gov/laws-rules-decisions/rulings-tax-commissioner/15-240",
              "cell_locator": "VA.llc.treatment.pass_through_entity_withholding_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.pass_through_entity_withholding_tax",
              "value": "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."
            }
          },
          "jurisdiction": "VA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://law.lis.virginia.gov/vacodefull/title58.1/chapter3/article16.1/",
          "state": "Virginia"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-57": {
      "field_definitions": {
        "base_tax_locator.permanent_building_fund_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.permanent_building_fund_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.permanent_building_fund_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.permanent_building_fund_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.permanent_building_fund_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.permanent_building_fund_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-57",
      "rows": [
        {
          "cells": {
            "base_tax_locator.permanent_building_fund_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3082/",
              "cell_locator": "ID.llc.base_tax_locator.permanent_building_fund_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.permanent_building_fund_tax",
              "value": "The additional return-filing tax and its composite-return extension are located in §63-3082; no amount is transcribed here."
            },
            "does_not_reach.permanent_building_fund_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3083/",
              "cell_locator": "ID.llc.does_not_reach.permanent_building_fund_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.permanent_building_fund_tax",
              "value": "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)."
            },
            "effective_period.permanent_building_fund_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3082/",
              "cell_locator": "ID.llc.effective_period.permanent_building_fund_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.permanent_building_fund_tax",
              "value": "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."
            },
            "filing_rule.permanent_building_fund_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3082/",
              "cell_locator": "ID.llc.filing_rule.permanent_building_fund_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.permanent_building_fund_tax",
              "value": "The additional tax is tied to the obligation to file an income-tax return and is paid by the return filer."
            },
            "tax_regime.permanent_building_fund_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3082/",
              "cell_locator": "ID.llc.tax_regime.permanent_building_fund_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.permanent_building_fund_tax",
              "value": "Every person required to file an Idaho income-tax return pays the additional excise tax imposed by §63-3082."
            },
            "treatment.permanent_building_fund_tax": {
              "cell_citation_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3083/",
              "cell_locator": "ID.llc.treatment.permanent_building_fund_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.permanent_building_fund_tax",
              "value": "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))."
            }
          },
          "jurisdiction": "ID",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.idaho.gov/statutesrules/idstat/Title63/T63CH30/SECT63-3082/",
          "state": "Idaho"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-58": {
      "field_definitions": {
        "base_tax_locator.personal_holding_company_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.personal_holding_company_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.personal_holding_company_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.personal_holding_company_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.personal_holding_company_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.personal_holding_company_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-58",
      "rows": [
        {
          "cells": {
            "base_tax_locator.personal_holding_company_tax": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.base_tax_locator.personal_holding_company_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.personal_holding_company_tax",
              "value": "The Alaska rate is located at AS 43.20.021(b) and Form 6000 Schedule E, line 4; the incorporated federal base is referenced to IRC §§ 541 and 545."
            },
            "does_not_reach.personal_holding_company_tax": {
              "cell_citation_url": "https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapG-partII-sec542.htm",
              "cell_locator": "AK.llc.does_not_reach.personal_holding_company_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.personal_holding_company_tax",
              "value": "The incorporated definition excludes the listed exempt, banking, insurance, surety, and foreign corporations; further specialized exceptions follow in IRC § 542(c)."
            },
            "effective_period.personal_holding_company_tax": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.effective_period.personal_holding_company_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.personal_holding_company_tax",
              "value": "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."
            },
            "filing_rule.personal_holding_company_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.filing_rule.personal_holding_company_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.personal_holding_company_tax",
              "value": "A personal holding company reports the add-on on Form 6000 Schedule E, line 4, with apportionment when appropriate."
            },
            "tax_regime.personal_holding_company_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.tax_regime.personal_holding_company_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.personal_holding_company_tax",
              "value": "Alaska assesses a personal-holding-company tax in addition to ordinary corporation tax and uses the Alaska statutory rate."
            },
            "treatment.personal_holding_company_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.treatment.personal_holding_company_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.personal_holding_company_tax",
              "value": "A qualifying personal holding company calculates ordinary Alaska corporation tax and a separate add-on reported on Schedule E."
            }
          },
          "jurisdiction": "AK",
          "last_checked": "2026-10-03",
          "official_source_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
          "state": "Alaska"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-59": {
      "field_definitions": {
        "base_tax_locator.personal_property_tax_replacement_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
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        "effective_period.personal_property_tax_replacement_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.personal_property_tax_replacement_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.personal_property_tax_replacement_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.personal_property_tax_replacement_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-59",
      "rows": [
        {
          "cells": {
            "base_tax_locator.personal_property_tax_replacement_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.base_tax_locator.personal_property_tax_replacement_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.personal_property_tax_replacement_income_tax",
              "value": "The replacement-tax imposition is located at 35 ILCS 5/201(c), and the corporation, partnership, trust, and S-corporation rates at subsection (d)."
            },
            "does_not_reach.personal_property_tax_replacement_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html",
              "cell_locator": "IL.llc.does_not_reach.personal_property_tax_replacement_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.personal_property_tax_replacement_income_tax",
              "value": "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."
            },
            "effective_period.personal_property_tax_replacement_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.effective_period.personal_property_tax_replacement_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.personal_property_tax_replacement_income_tax",
              "value": "The replacement tax begins July 1, 1979 for taxable years ending after June 30, 1979; subsection (d) states the later rate periods."
            },
            "filing_rule.personal_property_tax_replacement_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K502.html",
              "cell_locator": "IL.llc.filing_rule.personal_property_tax_replacement_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.personal_property_tax_replacement_income_tax",
              "value": "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."
            },
            "tax_regime.personal_property_tax_replacement_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
              "cell_locator": "IL.llc.tax_regime.personal_property_tax_replacement_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.personal_property_tax_replacement_income_tax",
              "value": "Illinois imposes the Personal Property Tax Replacement Income Tax, measured by net income, on every stated corporation, partnership, and trust."
            },
            "treatment.personal_property_tax_replacement_income_tax": {
              "cell_citation_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K1501.html",
              "cell_locator": "IL.llc.treatment.personal_property_tax_replacement_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.personal_property_tax_replacement_income_tax",
              "value": "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."
            }
          },
          "jurisdiction": "IL",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.ilga.gov/ftp/ILCS/Ch%200035/Act%200005/003500050K201.html",
          "state": "Illinois"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-60": {
      "field_definitions": {
        "base_tax_locator.qualified_entity_election": "The exact base-tax locator for this state, LLC, and rule variant.",
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        "effective_period.qualified_entity_election": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.qualified_entity_election": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.qualified_entity_election": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.qualified_entity_election": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-02",
      "matrix_id": "pp-holding-entity-tax:state-tax-60",
      "rows": [
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          "cells": {
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              "cell_locator": "SC.llc.base_tax_locator.qualified_entity_election",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.qualified_entity_election",
              "value": "The rate schedule for the qualified-entity election is located at S.C. Code § 12-6-545(B)(2)."
            },
            "does_not_reach.qualified_entity_election": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.does_not_reach.qualified_entity_election",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.qualified_entity_election",
              "value": "The active-trade-or-business definition excludes passive investment income, related expense, capital gains and losses, service payments, and stated personal-service amounts."
            },
            "effective_period.qualified_entity_election": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.effective_period.qualified_entity_election",
              "publish_status": "publish_ready",
              "source_field": "effective_period.qualified_entity_election",
              "value": "The qualified-entity election first applies to tax years beginning after 2020."
            },
            "filing_rule.qualified_entity_election": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.filing_rule.qualified_entity_election",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.qualified_entity_election",
              "value": "The annual election is due with the applicable return; owner exclusion depends on the qualified entity properly filing and paying the elected tax."
            },
            "tax_regime.qualified_entity_election": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.tax_regime.qualified_entity_election",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.qualified_entity_election",
              "value": "A qualified entity may elect annually to have tax imposed on the entity's active trade or business income."
            },
            "treatment.qualified_entity_election": {
              "cell_citation_url": "https://www.scstatehouse.gov/code/t12c006.php",
              "cell_locator": "SC.llc.treatment.qualified_entity_election",
              "publish_status": "publish_ready",
              "source_field": "treatment.qualified_entity_election",
              "value": "Passive investment income is outside the elected entity-level active-trade-or-business base; the statute does not label the entity itself exempt."
            }
          },
          "jurisdiction": "SC",
          "last_checked": "2026-10-02",
          "official_source_url": "https://www.scstatehouse.gov/code/t12c006.php",
          "state": "South Carolina"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-61": {
      "field_definitions": {
        "base_tax_locator.s_corporation_built_in_gains_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.s_corporation_built_in_gains_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.s_corporation_built_in_gains_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.s_corporation_built_in_gains_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.s_corporation_built_in_gains_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.s_corporation_built_in_gains_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-61",
      "rows": [
        {
          "cells": {
            "base_tax_locator.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.base_tax_locator.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_built_in_gains_tax",
              "value": "The imposition, lesser-of taxable-net-income computation, loss carryforward, and rate locator are in §290.9727, subds. 1-4; no amount is transcribed here."
            },
            "does_not_reach.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.does_not_reach.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_built_in_gains_tax",
              "value": "The subdivision does not apply when the corporation had an S election in effect for every taxable year; predecessor status is combined."
            },
            "effective_period.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.effective_period.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_built_in_gains_tax",
              "value": "The stated S-election condition is an election after December 31, 1986."
            },
            "filing_rule.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.filing_rule.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_built_in_gains_tax",
              "value": "An S corporation files a return for each taxable year in which its federal S election is in effect."
            },
            "tax_regime.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.tax_regime.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_built_in_gains_tax",
              "value": "Minnesota taxes recognized built-in gain of an S corporation with a post-1986 S election at the corporate rate."
            },
            "treatment.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.treatment.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_built_in_gains_tax",
              "value": "The qualifying built-in gain is taxed at the corporate rate notwithstanding the general S-corporation exemption in §290.9725."
            }
          },
          "jurisdiction": "MN",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
          "state": "Minnesota"
        },
        {
          "cells": {
            "base_tax_locator.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.base_tax_locator.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_built_in_gains_tax",
              "value": "Article IV §§401(3)1(p) and 402(b) locate the built-in-gain tax base and corporate net income tax rate schedule."
            },
            "does_not_reach.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.does_not_reach.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_built_in_gains_tax",
              "value": "The Article IV taxable-income definition reaches only net recognized built-in gain as federally determined under §1374(d)(2)."
            },
            "effective_period.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.effective_period.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_built_in_gains_tax",
              "value": "The Pennsylvania S-corporation built-in-gain taxable-income rule applies to taxable years beginning on or after January 1, 1998."
            },
            "filing_rule.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.filing_rule.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_built_in_gains_tax",
              "value": "A Pennsylvania S-corporation return is due thirty days after the federal corporate income-tax return due date."
            },
            "tax_regime.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.tax_regime.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_built_in_gains_tax",
              "value": "For a Pennsylvania S corporation, Article IV taxable income is federally determined net recognized built-in gain."
            },
            "treatment.s_corporation_built_in_gains_tax": {
              "cell_citation_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
              "cell_locator": "PA.llc.treatment.s_corporation_built_in_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_built_in_gains_tax",
              "value": "For a Pennsylvania S corporation, Article IV substitutes federally determined net recognized built-in gain as taxable income."
            }
          },
          "jurisdiction": "PA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1971/0/0002..HTM",
          "state": "Pennsylvania"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-62": {
      "field_definitions": {
        "base_tax_locator.s_corporation_capital_gains_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.s_corporation_capital_gains_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.s_corporation_capital_gains_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.s_corporation_capital_gains_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.s_corporation_capital_gains_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.s_corporation_capital_gains_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-62",
      "rows": [
        {
          "cells": {
            "base_tax_locator.s_corporation_capital_gains_tax": {
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              "cell_locator": "MN.llc.base_tax_locator.s_corporation_capital_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_capital_gains_tax",
              "value": "The imposition, corporate-rate reference, and lesser-of capital-gain income base are located in §290.9728, subds. 1-2; no amount is transcribed here."
            },
            "does_not_reach.s_corporation_capital_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.does_not_reach.s_corporation_capital_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_capital_gains_tax",
              "value": "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."
            },
            "effective_period.s_corporation_capital_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.effective_period.s_corporation_capital_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_capital_gains_tax",
              "value": "Eligibility is limited to an S corporation whose federal S election was made before January 1, 1987, subject to the stated lookback exclusions."
            },
            "filing_rule.s_corporation_capital_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.filing_rule.s_corporation_capital_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_capital_gains_tax",
              "value": "An S corporation files a return for each taxable year in which its federal S election is in effect."
            },
            "tax_regime.s_corporation_capital_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.tax_regime.s_corporation_capital_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_capital_gains_tax",
              "value": "Minnesota imposes an entity tax on a legacy S corporation meeting the pre-1987 election and capital-gain thresholds."
            },
            "treatment.s_corporation_capital_gains_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.treatment.s_corporation_capital_gains_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_capital_gains_tax",
              "value": "A qualifying legacy S corporation pays entity-level tax at the corporate rate on the lesser statutory capital-gain income base."
            }
          },
          "jurisdiction": "MN",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
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        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-63": {
      "field_definitions": {
        "base_tax_locator.s_corporation_entity_level_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
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        "effective_period.s_corporation_entity_level_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.s_corporation_entity_level_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.s_corporation_entity_level_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.s_corporation_entity_level_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-63",
      "rows": [
        {
          "cells": {
            "base_tax_locator.s_corporation_entity_level_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.base_tax_locator.s_corporation_entity_level_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_entity_level_tax",
              "value": "The entity-level base and corporate-rate cross-reference are located in §235-122(b); no amount is transcribed here."
            },
            "does_not_reach.s_corporation_entity_level_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.does_not_reach.s_corporation_entity_level_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_entity_level_tax",
              "value": "Outside the stated federally taxed-income exception, an S corporation is not subject to the corporation tax imposed by §235-71."
            },
            "effective_period.s_corporation_entity_level_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.effective_period.s_corporation_entity_level_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_entity_level_tax",
              "value": "No current effective or sunset period for the Part VII entity-level exception was stated in the complete chapter 235 capture."
            },
            "filing_rule.s_corporation_entity_level_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.filing_rule.s_corporation_entity_level_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_entity_level_tax",
              "value": "An S corporation files an annual Hawaii return when its Hawaii activities would require a C corporation return under §235-92."
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            "tax_regime.s_corporation_entity_level_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.tax_regime.s_corporation_entity_level_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_entity_level_tax",
              "value": "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."
            },
            "treatment.s_corporation_entity_level_tax": {
              "cell_citation_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
              "cell_locator": "HI.llc.treatment.s_corporation_entity_level_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_entity_level_tax",
              "value": "Federally taxed S-corporation income attributable to Hawaii is taxed at the highest marginal corporate rate and then reduces state-attributable S-corporation income."
            }
          },
          "jurisdiction": "HI",
          "last_checked": "2026-10-03",
          "official_source_url": "https://files.hawaii.gov/tax/legal/hrs/hrs_235.pdf",
          "state": "Hawaii"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-64": {
      "field_definitions": {
        "base_tax_locator.s_corporation_excess_net_passive_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.s_corporation_excess_net_passive_income_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.s_corporation_excess_net_passive_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.s_corporation_excess_net_passive_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.s_corporation_excess_net_passive_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.s_corporation_excess_net_passive_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-64",
      "rows": [
        {
          "cells": {
            "base_tax_locator.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.base_tax_locator.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_excess_net_passive_income_tax",
              "value": "The Alaska incorporation and return locator are AS 43.20.021(a) and Schedule E line 6; IRC § 1375(a)-(b) contains the base computation."
            },
            "does_not_reach.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapS-partIII-sec1375.htm",
              "cell_locator": "AK.llc.does_not_reach.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_excess_net_passive_income_tax",
              "value": "The conditional text does not impose the tax without both year-end accumulated earnings and profits and passive receipts above 25% of gross receipts."
            },
            "effective_period.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.effective_period.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_excess_net_passive_income_tax",
              "value": "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."
            },
            "filing_rule.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.filing_rule.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_excess_net_passive_income_tax",
              "value": "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."
            },
            "tax_regime.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.tax_regime.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_excess_net_passive_income_tax",
              "value": "Alaska imposes the incorporated excess-net-passive-income tax on an S corporation at the stated Alaska marginal rate."
            },
            "treatment.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
              "cell_locator": "AK.llc.treatment.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_excess_net_passive_income_tax",
              "value": "Although ordinary pass-through items are not taxed to the S corporation, Alaska separately taxes excess net passive income at the stated corporate rate."
            }
          },
          "jurisdiction": "AK",
          "last_checked": "2026-10-03",
          "official_source_url": "https://tax.alaska.gov/programs/documentviewer/viewer.aspx?7531f",
          "state": "Alaska"
        },
        {
          "cells": {
            "base_tax_locator.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
              "cell_locator": "AR.llc.base_tax_locator.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_excess_net_passive_income_tax",
              "value": "The computation rate and transfer to Form AR1100PET are located at line 11 of the excess-net-passive-income worksheet."
            },
            "does_not_reach.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
              "cell_locator": "AR.llc.does_not_reach.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_excess_net_passive_income_tax",
              "value": "The line does not apply if the corporation has always been a Subchapter S corporation; the instructions also require all three listed liability conditions."
            },
            "effective_period.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
              "cell_locator": "AR.llc.effective_period.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_excess_net_passive_income_tax",
              "value": "The 2025 instructions identify 4.3% as the 2024 rate for this line-6 tax."
            },
            "filing_rule.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
              "cell_locator": "AR.llc.filing_rule.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_excess_net_passive_income_tax",
              "value": "Enter the tax on AR1100PET line 6 and attach a schedule showing the computation in the worksheet's line 1-11 format."
            },
            "tax_regime.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
              "cell_locator": "AR.llc.tax_regime.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_excess_net_passive_income_tax",
              "value": "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."
            },
            "treatment.s_corporation_excess_net_passive_income_tax": {
              "cell_citation_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
              "cell_locator": "AR.llc.treatment.s_corporation_excess_net_passive_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_excess_net_passive_income_tax",
              "value": "A qualifying S-corporation-classified LLC pays a separate entity-level tax on excess net passive income and reports it on AR1100PET line 6."
            }
          },
          "jurisdiction": "AR",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.dfa.arkansas.gov/wp-content/uploads/AR1100PET_Instructions_2025.pdf",
          "state": "Arkansas"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-65": {
      "field_definitions": {
        "base_tax_locator.s_corporation_minimum_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.s_corporation_minimum_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.s_corporation_minimum_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.s_corporation_minimum_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.s_corporation_minimum_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.s_corporation_minimum_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-65",
      "rows": [
        {
          "cells": {
            "base_tax_locator.s_corporation_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.base_tax_locator.s_corporation_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_minimum_tax",
              "value": "The S corporation minimum tax is located at 32 V.S.A. § 5915."
            },
            "does_not_reach.s_corporation_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.does_not_reach.s_corporation_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_minimum_tax",
              "value": "No holding- or passive-entity limit beyond the section 5914 scope was stated in the complete current S-corporation subchapter."
            },
            "effective_period.s_corporation_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.effective_period.s_corporation_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_minimum_tax",
              "value": "The current minimum-tax section reflects an amendment effective May 25, 2016."
            },
            "filing_rule.s_corporation_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.filing_rule.s_corporation_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_minimum_tax",
              "value": "The S corporation must file an annual return by the prescribed federal S-corporation return due date."
            },
            "tax_regime.s_corporation_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.tax_regime.s_corporation_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_minimum_tax",
              "value": "An S corporation subject to section 5914 must pay the annual minimum tax."
            },
            "treatment.s_corporation_minimum_tax": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.treatment.s_corporation_minimum_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_minimum_tax",
              "value": "Every S corporation subject to section 5914 must pay the annual minimum tax; no holding-entity carveout is stated."
            }
          },
          "jurisdiction": "VT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
          "state": "Vermont"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-66": {
      "field_definitions": {
        "base_tax_locator.s_corporation_nonresident_payment": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.s_corporation_nonresident_payment": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.s_corporation_nonresident_payment": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.s_corporation_nonresident_payment": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.s_corporation_nonresident_payment": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.s_corporation_nonresident_payment": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-66",
      "rows": [
        {
          "cells": {
            "base_tax_locator.s_corporation_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.base_tax_locator.s_corporation_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_nonresident_payment",
              "value": "The nonresident-shareholder payment formula is located at 32 V.S.A. § 5914(c)."
            },
            "does_not_reach.s_corporation_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.does_not_reach.s_corporation_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_nonresident_payment",
              "value": "The complete current S-corporation subchapter states no holding- or passive-entity exclusion from subsection 5914(c)."
            },
            "effective_period.s_corporation_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.effective_period.s_corporation_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_nonresident_payment",
              "value": "The current mandatory-payment section reflects an amendment effective January 1, 2023."
            },
            "filing_rule.s_corporation_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.filing_rule.s_corporation_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_nonresident_payment",
              "value": "The entity must file its annual S-corporation return by the prescribed federal due date."
            },
            "tax_regime.s_corporation_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.tax_regime.s_corporation_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_nonresident_payment",
              "value": "An S corporation is liable for Vermont income taxes imposed on nonresident shareholders with respect to its income."
            },
            "treatment.s_corporation_nonresident_payment": {
              "cell_citation_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
              "cell_locator": "VT.llc.treatment.s_corporation_nonresident_payment",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_nonresident_payment",
              "value": "The rule makes the S corporation liable with respect to each nonresident shareholder; no holding-entity carveout is stated."
            }
          },
          "jurisdiction": "VT",
          "last_checked": "2026-10-03",
          "official_source_url": "https://legislature.vermont.gov/statutes/fullchapter/32/151",
          "state": "Vermont"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-67": {
      "field_definitions": {
        "base_tax_locator.s_corporation_passive_investment_income_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.s_corporation_passive_investment_income_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.s_corporation_passive_investment_income_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.s_corporation_passive_investment_income_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.s_corporation_passive_investment_income_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.s_corporation_passive_investment_income_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-67",
      "rows": [
        {
          "cells": {
            "base_tax_locator.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
              "cell_locator": "CA.llc.base_tax_locator.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_passive_investment_income_tax",
              "value": "The rate is set by reference to R&TC § 23151 under § 23811(b)(1), with a financial-corporation adjustment in (b)(2); the base follows IRC § 1375 as modified."
            },
            "does_not_reach.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
              "cell_locator": "CA.llc.does_not_reach.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_passive_investment_income_tax",
              "value": "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."
            },
            "effective_period.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
              "cell_locator": "CA.llc.effective_period.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_passive_investment_income_tax",
              "value": "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."
            },
            "filing_rule.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=10.2.&chapter=2.&article=",
              "cell_locator": "CA.llc.filing_rule.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_passive_investment_income_tax",
              "value": "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))."
            },
            "tax_regime.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
              "cell_locator": "CA.llc.tax_regime.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_passive_investment_income_tax",
              "value": "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."
            },
            "treatment.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
              "cell_locator": "CA.llc.treatment.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_passive_investment_income_tax",
              "value": "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."
            }
          },
          "jurisdiction": "CA",
          "last_checked": "2026-10-02",
          "official_source_url": "https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=RTC&division=2.&title=&part=11.&chapter=4.5.&article=",
          "state": "California"
        },
        {
          "cells": {
            "base_tax_locator.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.base_tax_locator.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.s_corporation_passive_investment_income_tax",
              "value": "The imposition, corporate-rate reference, and lesser-of excess-net-passive-income base are in §290.9729, subds. 1-2; no amount is transcribed here."
            },
            "does_not_reach.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.does_not_reach.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.s_corporation_passive_investment_income_tax",
              "value": "The Minnesota tax is waived when the taxpayer receives the corresponding federal §1375(d) waiver."
            },
            "effective_period.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.effective_period.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.s_corporation_passive_investment_income_tax",
              "value": "No current sunset or effective period for the S-corporation passive-investment-income tax was stated in the complete chapter 290 capture."
            },
            "filing_rule.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/289A/pdf",
              "cell_locator": "MN.llc.filing_rule.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.s_corporation_passive_investment_income_tax",
              "value": "An S corporation files a return for each taxable year in which its federal S election is in effect."
            },
            "tax_regime.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.tax_regime.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.s_corporation_passive_investment_income_tax",
              "value": "Minnesota taxes an S corporation with accumulated C-corporation earnings and profits when passive investment income exceeds 25% of gross receipts."
            },
            "treatment.s_corporation_passive_investment_income_tax": {
              "cell_citation_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
              "cell_locator": "MN.llc.treatment.s_corporation_passive_investment_income_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.s_corporation_passive_investment_income_tax",
              "value": "A qualifying S corporation pays entity-level tax at the corporate rate on the lesser statutory excess-net-passive-income base."
            }
          },
          "jurisdiction": "MN",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.revisor.mn.gov/statutes/cite/290/pdf",
          "state": "Minnesota"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-68": {
      "field_definitions": {
        "base_tax_locator.security_corporation_excise": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.security_corporation_excise": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.security_corporation_excise": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.security_corporation_excise": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.security_corporation_excise": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.security_corporation_excise": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-68",
      "rows": [
        {
          "cells": {
            "base_tax_locator.security_corporation_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
              "cell_locator": "MA.llc.base_tax_locator.security_corporation_excise",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.security_corporation_excise",
              "value": "The security-corporation gross-income definition and excise measure are located in Chapter 63 §§ 30 and 38B."
            },
            "does_not_reach.security_corporation_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
              "cell_locator": "MA.llc.does_not_reach.security_corporation_excise",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.security_corporation_excise",
              "value": "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."
            },
            "effective_period.security_corporation_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
              "cell_locator": "MA.llc.effective_period.security_corporation_excise",
              "publish_status": "publish_ready",
              "source_field": "effective_period.security_corporation_excise",
              "value": "No special commencement or sunset period was located for the § 38B security-corporation classification or excise in the complete Chapter 63 search."
            },
            "filing_rule.security_corporation_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
              "cell_locator": "MA.llc.filing_rule.security_corporation_excise",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.security_corporation_excise",
              "value": "The corporation applies to the commissioner for security-corporation classification before the taxable year ends; the general Chapter 62C corporate-return rule also applies."
            },
            "tax_regime.security_corporation_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
              "cell_locator": "MA.llc.tax_regime.security_corporation_excise",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.security_corporation_excise",
              "value": "Section 38B imposes a gross-income-measured excise on a qualifying financial institution or business corporation classified as a security corporation."
            },
            "treatment.security_corporation_excise": {
              "cell_citation_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
              "cell_locator": "MA.llc.treatment.security_corporation_excise",
              "publish_status": "publish_ready",
              "source_field": "treatment.security_corporation_excise",
              "value": "A qualifying security corporation is outside the general § 39 excise and pays the separate gross-income-measured § 38B excise."
            }
          },
          "jurisdiction": "MA",
          "last_checked": "2026-10-03",
          "official_source_url": "https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section38B",
          "state": "Massachusetts"
        }
      ],
      "scope_label": "1 jurisdictions"
    },
    "state-tax-69": {
      "field_definitions": {
        "base_tax_locator.state_business_license_fee": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.state_business_license_fee": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.state_business_license_fee": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.state_business_license_fee": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.state_business_license_fee": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.state_business_license_fee": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-69",
      "rows": [
        {
          "cells": {
            "base_tax_locator.state_business_license_fee": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.base_tax_locator.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.state_business_license_fee",
              "value": "The annual business-license fee is located at AS 43.70.030(a); no amount is transcribed here."
            },
            "does_not_reach.state_business_license_fee": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.does_not_reach.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.state_business_license_fee",
              "value": "Chapter 70 exempts the activities of a qualifying educational investment club; that narrow exemption does not state a general holding-LLC exclusion."
            },
            "effective_period.state_business_license_fee": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.effective_period.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "effective_period.state_business_license_fee",
              "value": "No effective or sunset period for the current business-license fee was stated in complete Chapter 70."
            },
            "filing_rule.state_business_license_fee": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.filing_rule.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.state_business_license_fee",
              "value": "A person must apply on the prescribed form, obtain the license, and pay the fee before engaging in business in Alaska."
            },
            "tax_regime.state_business_license_fee": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.tax_regime.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.state_business_license_fee",
              "value": "A person engaging in business in Alaska must first obtain a business license and pay the statutory annual fee."
            },
            "treatment.state_business_license_fee": {
              "cell_citation_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
              "cell_locator": "AK.llc.treatment.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "treatment.state_business_license_fee",
              "value": "The license-fee statute reaches a person engaging in statutory business, and complete Chapter 70 contains no general holding- or passive-entity carve-out."
            }
          },
          "jurisdiction": "AK",
          "last_checked": "2026-10-03",
          "official_source_url": "https://www.akleg.gov/statutesPDF/Title-43.pdf",
          "state": "Alaska"
        },
        {
          "cells": {
            "base_tax_locator.state_business_license_fee": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
              "cell_locator": "NV.llc.base_tax_locator.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.state_business_license_fee",
              "value": "The license fee is set in NRS 76.100(2)(c) and the annual renewal fee in NRS 76.130(1)-(2); penalties are in NRS 76.110, 76.130(4) and 76.180."
            },
            "does_not_reach.state_business_license_fee": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
              "cell_locator": "NV.llc.does_not_reach.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.state_business_license_fee",
              "value": "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."
            },
            "effective_period.state_business_license_fee": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
              "cell_locator": "NV.llc.effective_period.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "effective_period.state_business_license_fee",
              "value": "NRS ch. 76 states no effective or sunset date for the state business license or its fee."
            },
            "filing_rule.state_business_license_fee": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
              "cell_locator": "NV.llc.filing_rule.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.state_business_license_fee",
              "value": "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."
            },
            "tax_regime.state_business_license_fee": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
              "cell_locator": "NV.llc.tax_regime.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.state_business_license_fee",
              "value": "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."
            },
            "treatment.state_business_license_fee": {
              "cell_citation_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
              "cell_locator": "NV.llc.treatment.state_business_license_fee",
              "publish_status": "publish_ready",
              "source_field": "treatment.state_business_license_fee",
              "value": "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."
            }
          },
          "jurisdiction": "NV",
          "last_checked": "2026-10-02",
          "official_source_url": "https://www.leg.state.nv.us/NRS/NRS-076.html",
          "state": "Nevada"
        }
      ],
      "scope_label": "2 jurisdictions"
    },
    "state-tax-70": {
      "field_definitions": {
        "base_tax_locator.unincorporated_business_franchise_tax": "The exact base-tax locator for this state, LLC, and rule variant.",
        "does_not_reach.unincorporated_business_franchise_tax": "The exact boundary field for what this state rule variant does not reach.",
        "effective_period.unincorporated_business_franchise_tax": "The exact effective-period field for this state, LLC, and rule variant.",
        "filing_rule.unincorporated_business_franchise_tax": "The exact filing-duty field for this state, LLC, and rule variant.",
        "tax_regime.unincorporated_business_franchise_tax": "The exact tax-regime field for this state, LLC, and rule variant.",
        "treatment.unincorporated_business_franchise_tax": "The exact treatment field for this state, LLC, and rule variant."
      },
      "last_updated": "2026-10-03",
      "matrix_id": "pp-holding-entity-tax:state-tax-70",
      "rows": [
        {
          "cells": {
            "base_tax_locator.unincorporated_business_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.base_tax_locator.unincorporated_business_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "base_tax_locator.unincorporated_business_franchise_tax",
              "value": "The unincorporated-business tax rate and minimum-tax provisions are located at D.C. Code § 47-1808.03(a)-(b)."
            },
            "does_not_reach.unincorporated_business_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.does_not_reach.unincorporated_business_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "does_not_reach.unincorporated_business_franchise_tax",
              "value": "The own-account exclusion does not cover dealer inventory, ordinary-course lender debt, or non-publicly-traded REIT stock or partnership interests."
            },
            "effective_period.unincorporated_business_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.effective_period.unincorporated_business_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "effective_period.unincorporated_business_franchise_tax",
              "value": "The own-account exclusion applies for tax years beginning after December 31, 2014."
            },
            "filing_rule.unincorporated_business_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.filing_rule.unincorporated_business_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "filing_rule.unincorporated_business_franchise_tax",
              "value": "Chapter 18 does not separately state a filing rule for an activity excluded from the unincorporated-business definition by the own-account carve-out."
            },
            "tax_regime.unincorporated_business_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.tax_regime.unincorporated_business_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "tax_regime.unincorporated_business_franchise_tax",
              "value": "The unincorporated-business franchise tax applies to every domestic or foreign unincorporated business for current taxable years."
            },
            "treatment.unincorporated_business_franchise_tax": {
              "cell_citation_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
              "cell_locator": "DC.llc.treatment.unincorporated_business_franchise_tax",
              "publish_status": "publish_ready",
              "source_field": "treatment.unincorporated_business_franchise_tax",
              "value": "A qualifying own-account holding activity is excluded from the statutory definition of an unincorporated business, subject to the stated exceptions."
            }
          },
          "jurisdiction": "DC",
          "last_checked": "2026-10-03",
          "official_source_url": "https://code.dccouncil.gov/us/dc/council/code/titles/47/chapters/18/index.full.html",
          "state": "District of Columbia"
        }
      ],
      "scope_label": "1 jurisdictions"
    }
  },
  "template": "matrix",
  "tier": "T1",
  "warnings": []
}