Georgia 2023-2024 Regular Session

Georgia House Bill HB412

Introduced
2/14/23  
Report Pass
3/2/23  
Introduced
2/14/23  
Engrossed
3/6/23  
Report Pass
3/2/23  
Refer
3/7/23  
Engrossed
3/6/23  
Report Pass
3/16/23  
Refer
3/7/23  
Enrolled
3/31/23  
Report Pass
3/16/23  
Chaptered
5/2/23  
Enrolled
3/31/23  
Chaptered
5/2/23  

Caption

Income tax; repeal a limitation on types of partnerships that may elect to pay income taxes at the entity level

Impact

The impact of HB 412 will be significant for partnerships that are structured as pass-through entities. By allowing these partnerships to elect tax payments at the entity level, it potentially reduces the tax burden on individual partners by excluding their respective shares of the income that the partnership pays tax on, thus simplifying individual tax filings. The bill specifically aims to eliminate a previous limitation on the types of partnerships that could make such an election, which could incentivize more partnerships to consider this election and thereby influence business taxation strategies across the state.

Summary

House Bill 412 proposes amendments to Chapter 7 of Title 48 of the Official Code of Georgia Annotated to modify regulations surrounding income taxes for partnerships. Specifically, the bill allows partnerships to make an irrevocable election to pay income taxes at the entity level, effectively treating the partnership itself as the taxpayer, rather than the individual partners. This change aims to simplify tax obligations for certain pass-through entities, which can lead to clearer tax treatment and compliance for partnerships that qualify under the new provisions.

Sentiment

The sentiment surrounding HB 412 appears largely positive among supporters, primarily composed of business owners and tax professionals who argue that this change will streamline the tax process and improve financial clarity for partnerships. However, there exists some concern that this may complicate the tax landscape for smaller partnerships or lead to unforeseen ramifications in tax law interpretation, which may have drawn some scrutiny from critics.

Contention

Notable points of contention may arise from the interpretation of how this bill could affect partnerships that do not qualify as 'S Corporations' under federal tax law. Critics worry that the bill might inadvertently exclude certain partnerships from benefiting from the election, or create complexity in tax treatment between different types of partnerships. Additionally, the repeal of limitations on electing partnerships could raise questions about equity and fairness in taxation among similarly structured entities—considerations that remain heated in ongoing legislative debates.

Companion Bills

No companion bills found.

Previously Filed As

GA SB790

Income taxes: partnerships: audit adjustments: elections.

GA HB3245

Providing an election for pass-through entities to pay income tax at the entity level

GA B26-0324

Pass-Through Entities Income Tax and Tax Credit on Certain S Corporations and Partnerships Amendment Act of 2025

GA HB1121

Income tax, state; pass-through entities, elective tax.

GA SB692

Income tax, state; pass-through entities, elective tax.

GA SB442

Providing option for pass-through entities to pay income tax at entity level

GA HB2608

Allow pass-through entities to elect to be taxed at the entity level

GA HB1023

Income tax; match tax rate imposed on corporations to that imposed on individual taxpayers

GA SB496

Allowing tax pass through entities to pay state and local taxes at entity level

GA HB1456

Income tax, state; pass-through entities.

Similar Bills

DE SB112

An Act To Amend Title 6 Of The Delaware Code Relating To The Creation, Regulation, Operation, And Dissolution Of Domestic Limited Partnerships And The Registration And Regulation Of Foreign Limited Partnerships.

DE SB115

An Act To Amend Title 6 Of The Delaware Code Relating To The Creation, Regulation, Operation, And Dissolution Of Domestic Partnerships And The Registration And Regulation Of Foreign Limited Liability Partnerships.

CA AB1862

Engineering, land surveying, and architecture: limited liability partnerships.

CA SB920

Engineering, land surveying, and architecture: limited liability partnerships.

TN SB1174

AN ACT to amend Tennessee Code Annotated, Title 48 and Title 61, relative to registered agents.

TN HB0349

AN ACT to amend Tennessee Code Annotated, Title 48 and Title 61, relative to registered agents.

RI H7603

Uniform Limited Partnership Act

RI S2812

Uniform Limited Partnership Act