Core Points - The American Institute of CPAs (AICPA) has provided additional feedback on sourcing rules for partnership income to the Multistate Tax Commission (MTC) [1][2] - The AICPA's letter addresses concerns regarding the impact of these rules on state taxation of partnership income and the sourcing process [3][4] Group 1 - The letter suggests adjustments to the MTC's draft white paper, focusing on partnership structures, special allocations, and related-party transactions [2][4] - AICPA requests a clear definition of guidelines for partnerships calculating entry-level taxes [3] - Recommendations include addressing differences in sourcing rules for non-resident or corporate partners [4] Group 2 - The letter highlights the need for clarification on why sourcing guidance is applied at the partner level rather than the partnership level [4] - AICPA suggests including the DC Circuit Court's decision in Rawat v Commissioner of Internal Revenue to aid in determining the nature of a partner's gain [5] - Additional guidance is requested for situations where partners act outside their official capacities [6] Group 3 - The letter calls for establishing whether a taxpayer operates a trade or business before determining if it constitutes a unitary business [6] - AICPA emphasizes the complexity faced by taxpayers and practitioners regarding partnership structures and related-party transactions [7]