SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

Recording of a 110-minute CPE webinar with Q&A

Conducted on Thursday, February 22, 2018

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE course will offer tax professionals insight and guidance on state tax implications for transactions and activities of multinational businesses. The panel will discuss the impact of deemed tax residency, business apportionment, certain selective add-backs to income, tax implications arising from international provisions of federal tax reform, and planning methods related to state and local taxation of foreign corporation revenue within a given forum.


State tax collection initiatives on foreign and domestic business activities are as prevalent as business planning efforts on federal income and employment taxes. Selective add-backs, tax haven legislation and combined reporting based on the unitary business approach, subjecting subsidiaries and affiliates or their income to state taxation, are the most aggressive approaches for states to increase revenues from foreign transactions and foreign corporations.

Recent changes to the federal taxation raise conformity challenges for the states, as well as constitutional limitations on the states’ abilities to benefit from the federal changes. Knowledge of state tax legislation and tax planning methods are essential elements of corporate income tax compliance and reporting.

Listen as our panel discusses and provides an analysis of the impact of state tax legislation on foreign corporations, effective compliance procedures, business apportionment rules, and limiting multinational corporations’ state reporting of business activities within the U.S.



  1. Analysis and impact of tax residency status and establishing procedures for forum compliance
  2. State subjection of foreign corporations and subsidiaries to taxation, including unitary taxation
  3. Business apportionment and waters-edge election
  4. State tax-haven legislation updates
  5. Preliminary observations on state and local tax implications of federal tax reform


The panel will review these and other key issues:

  • Recognizing the exposure and effect of state taxation on foreign corporations
  • Identifying state tax legislation and reporting requirements of subsidiaries and affiliated groups
  • Ascertaining the available methods to reduce and limit state tax liability


Rimkunas, Dennis
Dennis Rimkunas

Jones Day

Mr. Rimkunas focuses his practice on tax planning and litigation relating to state and local tax matters for...  |  Read More

Wynne, Michael
Michael J. (Mike) Wynne

Jones Day

Mr. Wynne has more than 30 years of experience in state and local tax litigation, planning, legislative, and regulatory...  |  Read More

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