Connecticut Administrative Code › Title 12 - Taxation › 740(a) - INCOME TAX › Part III - Part-year Resident individuals & trusts › Section 12-717-4 - Part-year residents: distributive or pro rata share of partners and S corporation shareholders

Current through July 10, 2024
(a)
Partners
. Where an individual is a partner in a partnership and
				such individual changes resident status during the taxable year, the partner's
				distributive share of partnership income, gain, loss and deduction, and any
				modifications relating thereto described in §
									12-715(a)-1
				of Part VII, to be included in the determination of the numerator of the
				partner's Connecticut source fraction under §
									12-700(c)-1
				of this Part shall be the total of:
(1) the
				partner's distributive share of partnership income, gain, loss and deduction
				included in the partner's Connecticut adjusted gross income prorated to the
				partner's period of residence in accordance with the number of days such
				individual was a resident of Connecticut; and
(2) the partner's distributive share of
				partnership income, gain, loss and deduction included in the partner's
				Connecticut adjusted gross income prorated to the partner's period of
				nonresidence in accordance with the number of days such individual was a
				nonresident of Connecticut, but only to the extent such prorated amount of
				income, gain, loss and deduction is derived from or connected with Connecticut
				sources.
(3) Examples.
Example 1
: D, an unmarried cash basis taxpayer,
				  filed a 2001 federal income tax return on a calendar year basis and properly
				  reported thereon federal adjusted gross income of $50,000, $40,000 of which was
				  from the R Partnership, whose taxable year ended on December 31, 2001. The R
				  Partnership carried on business both within and without Connecticut and 60% of
				  its income, gain, loss and deduction for such year was derived from or
				  connected with Connecticut sources. D was a resident of Connecticut from
				  January 1, 2001 through July 31, 2001 and became a nonresident on August 1,
				  2001. The balance ($10,000) of D's federal adjusted gross income was
				  attributable to his period of nonresidence and was not derived from or
				  connected with Connecticut sources. D's Connecticut adjusted gross income
				  equals his federal adjusted gross income.
Based on the foregoing, D shall file a Connecticut part-year
				  resident income tax return for the taxable year. D's tentative Connecticut
				  income tax liability under §
											12-700(c)-1,
				  determined as if D were a resident, is $1,932 (based on Connecticut adjusted
				  gross income of $50,000). The numerator of the Connecticut source fraction is
				  the sum of (i) D's distributive share of partnership income, gain, loss and
				  deduction included in his Connecticut adjusted gross income prorated to the
				  period of D's residence in accordance with the number of days (212) D was a
				  resident ($40,000 multiplied by 212/365) and (ii) D's distributive share of
				  partnership income, gain, loss and deduction included in his Connecticut
				  adjusted gross income prorated to the period of D's nonresidence in accordance
				  with the number of days (153) D was a nonresident, but only to the extent such
				  prorated amount of income, gain, loss and deduction was derived from or
				  connected with Connecticut sources ($40,000 multiplied by 153/365 multiplied by
				  60%), and the denominator is D's Connecticut adjusted gross income ($50,000).
				  D's Connecticut income tax is $1,286, determined by multiplying the tentative
				  Connecticut income tax ($1,932) by the Connecticut source fraction
				  ($33,293/$50,000).
Example 2
: Assume the same facts as in Example 1
				  except that the R partnership's taxable year ended on May 31, 2001 and E, an
				  unmarried cash basis taxpayer who was also a partner in the R Partnership and
				  who filed a 2001 federal income tax return on a calendar year basis and
				  properly reported thereon federal adjusted gross income of $50,000, $40,000 of
				  which was from the R Partnership, was a nonresident of Connecticut from January
				  1, 2001 through September 30, 2001 and became a resident on October 1, 2001.
				  The balance ($10,000) of E's federal adjusted gross income was attributable to
				  her period of nonresidence and was not derived from or connected with
				  Connecticut sources. E's Connecticut adjusted gross income equals her federal
				  adjusted gross income.
Based on the foregoing, E's tentative Connecticut income tax
				  liability under §
											12-700(c)-1,
				  determined as if E were a resident, is the same as in Example 1 $1,932. The
				  denominator of the Connecticut source fraction is also the same as in Example 1
				  (Connecticut adjusted gross income of $50,000). The numerator of the
				  Connecticut source fraction is the sum of (i) E's distributive share of
				  partnership income, gain, loss and deduction included in her Connecticut
				  adjusted gross income prorated to the period of E's residence in accordance
				  with the number of days (92) E was a resident ($40,000 multiplied by 92/365)
				  and (ii) E's distributive share of partnership income, gain, loss and deduction
				  included in her Connecticut adjusted gross income prorated to the period of E's
				  nonresidence in accordance with the number of days (273) E was a nonresident,
				  but only to the extent such prorated amount of income, gain, loss and deduction
				  was derived from or connected with Connecticut sources ($40,000 multiplied by
				  273/365 multiplied by 60%). E's Connecticut income tax is $1,083, determined by
				  multiplying the tentative Connecticut income tax ($1,932) by the Connecticut
				  source fraction ($28,033/$50,000).