Tax Type
Individual Income Tax
Description
Nonresident partnership
Topic
Returns/Payments/Records
Date Issued
02-27-1987
February 27, 1987
Re: Ruling Request
Partnership Income
Dear ****************
This is in reply to your letter of March 31, 1986 and your subsequent conversations with members of the department's Tax Policy Division, in which you requested permission to exempt the Maryland partners of ********** (Partnership) from the requirement of filing a Virginia nonresident individual income tax return for taxable years 1985 and 1986.
The Partnership was created by the combination of a Virginia professional corporation with a Maryland partnership. The agreement under which the two entities agreed to combine into a single Maryland partnership specifies that for a period of two years the Maryland partners will not share or benefit in any income earned by the Virginia office. The partnership returns for both years have been filed and it appears that the income of the Virginia office was distributed in accordance with the agreement. Due to the unique nature of the partnership agreement and under the authority granted by Virginia Regulation 630-4-491, the department agrees to exempt the Maryland resident partners of the Partnership, without other income from Virginia sources, from the requirement of filing a Virginia nonresident individual income tax return for taxable years 1985 and 1986 only.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner