No, only a recognized partnership (i.e., two or more members) or an S corporation is eligible to make a deductible state income tax payment and pass through the payment to its owners as a tax credit for state income tax reporting purposes. (See Notice 2020-75.) In fact, we commonly explore with clients whether it makes sense to convert a single-member LLC to a multi-member LLC (e.g., via a small gift to a spouse or other family member) to obtain the PTE benefits.
Q. Is an individual eligible for a pass-through entity tax (“PTE”) deduction when the business is operated in a single-member LLC?
A.