South Carolina DOR Issues Private Letter Ruling on Sale of Multistate Partnership Interest

The South Carolina Department of Revenue (DOR) issued a private letter ruling on the sale of a multistate partnership interest. The taxpayer was an active owner of tiered pass-through entities comprised of two limited liability companies treated as partnerships for tax purposes. The Taxpayer was a partner in “Management Partnership,” which owned 49 percent of “Operating Partnership.” The partnerships conducted business in multiple states, including South Carolina. The DOR ruled that the 2.4 percent proportion of the taxpayer’s business carried on in the state required apportioning 2.4 percent of any gain to South Carolina not directly allocated under S.C. Code ...