Form Ct-1065 - Connecticut Partnership Income Tax Return And Instructions - 2003 Page 14

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Schedule E - Computation of
special allocations are subject to review by the
Commissioner of Revenue Services.
Connecticut Source Income
The character of the income (loss) for Connecticut
Complete Schedule E for each partner that is a resident
purposes must mirror the character of such income
trust or estate; a nonresident individual, trust, or estate;
(loss) on the federal return.
a partnership; or an S corporation.
Clearly indicate a loss by using parentheses ( ).
A partnership that maintains books and records that
satisfactorily disclose the portion of its income, gain,
Line 1 - Ordinary Income (Loss) From Trade or
loss, or deduction derived from or connected with
Business Activities
Connecticut sources must enter the amount of each
Enter the Connecticut portion of the amount of each
nonresident partner's distributive share of partnership
partner’s distributive share of the ordinary income (loss)
items derived from or connected with Connecticut
from the trade or business activities of the partnership.
sources as determined from those books and records.
Unless the partnership maintains books and records that
The portion of the partnership's income, gain, loss, or
satisfactorily disclose the portion of income, gain, loss,
deduction that is derived from or connected with
or deduction derived from or connected with Connecticut
Connecticut sources (as determined from the
sources, this amount is calculated by multiplying the
partnership's books and records) will be multiplied by
partner's ordinary income (loss) from the trade or
the partner’s distributive share (%) of that income, gain,
business from the partner's federal Form 1065, Schedule
loss, or deduction.
K-1, by the apportionment fraction on Schedule B,
A partnership that does not maintain books and records
Line 8.
that satisfactorily disclose the portion of income, gain,
Line 2 and Line 3 - Net Income (Loss)
loss, or deduction derived from or connected with
Connecticut sources must use the apportionment
Enter the Connecticut portion of the amount of each
fraction computed on Schedule B, Line 8, or an
partner's distributive share attributable to rental activities.
authorized alternate method, to determine the portion
Amounts attributable to real property located in
of each nonresident partner's distributive share of any
Connecticut are 100% taxable to a nonresident partner
item that is derived from or connected with Connecticut
for Connecticut income tax purposes. Amounts
sources. This is accomplished by multiplying federal
attributable to real property located outside Connecticut
Form 1065, Schedule K-1 distributive share amounts
are not taxable to a nonresident partner for Connecticut
for each partner by the apportionment fraction as
income tax purposes.
reported on Schedule B, Line 8, and entering the result
on Schedule E.
Line 4 - Portfolio Income (Loss)
Enter the Connecticut portion of the amount of each
The amounts entered for a partner on Schedule E should
include the Connecticut modifications reported for the
partner's distributive share of portfolio income (loss).
Items of income, gain, loss, and deduction derived from
partner on Schedule D to the extent those modifications
are derived from or connected with Connecticut sources.
or connected with Connecticut sources do not include
such items attributable to intangible personal property
Special limitations on partnership agreements: If a
except to the extent such intangible property is employed
partnership agreement provides for a special allocation
in a business, trade, profession, or occupation carried
among the partners of any item of partnership income,
on in Connecticut. For example, dividends from stock
gain, loss, or deduction, federal income tax law requires
used as collateral to secure a business loan for a
that such a provision be disregarded for federal income
Connecticut business would be income from intangible
tax purposes, where its principal purpose is the avoidance
property employed in a Connecticut trade or business
or evasion of federal income tax. In such a case, each
and therefore would be taxable for Connecticut income
partner's distributive share of that item is determined by
tax purposes to a nonresident partner.
the partner's distributive share for federal income tax
purposes of the taxable income or loss of the partnership
Line 5 - Guaranteed Payments to Partners
as described in I.R.C. §702(a)(8). This treatment and
Enter the Connecticut portion of the amount of each
distribution of the item is reflected in each partner’s
partner's distributive share of guaranteed payments made
federal adjusted gross income and therefore, in each
to the partner. Unless the partnership maintained books
partner's Connecticut adjusted gross income, even
and records that satisfactorily disclose the portion of
though in a particular case no Connecticut income tax
income, gain, loss, or deduction derived from or
avoidance or evasion may be involved.
connected with Connecticut sources, this is calculated
In certain cases, however, a provision for special
by multiplying the amount of the partner's distributive
allocation does not have as its principal purpose the
share of guaranteed payments from federal Form 1065,
avoidance or evasion of federal income tax, but has as
Schedule K-1, by the apportionment fraction on
its principal purpose the avoidance or evasion of
Schedule B, Line 8.
Connecticut income tax. In such an instance, such
Page 14

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