State Taxation of Foreign Income: Section 163(j), GILTI, Section 250 Deduction, Repatriation Payments

Note: CLE credit is not offered on this program

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

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Conducted on Thursday, October 1, 2020

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Course Materials

This course will discuss the multitude of differences in state requirements for reporting foreign income. Our panel of experts in foreign income tax matters will explain the latest developments in state taxation of GILTI income, the corresponding Section 250 deduction, and Section 965 repatriation payments for practitioners and advisers reporting foreign income in multiple states.


There are multiple methods employed by states to tax, or not tax, foreign income. GILTI income may be included unadjusted as part of federal taxable income in some states. States may allow a subtraction from federal taxable income and a corresponding addition of the GILTI Section 250 deduction. Other states have developed unique criteria for GILTI taxation with Tennessee, for example, requiring a five percent addback of GILTI income and Maine allowing a 50 percent deduction for the amounts included in state income.

Many of the decisions surrounding taxability and reporting foreign income have stalled due to the 2020 pandemic. At the same time, SALT practitioners must be aware of the latest state developments surrounding taxation of foreign income to report tax accurately and avoid penalties in states that tax foreign income.

In addition to Section 951A income, there are significant differences in state taxation of repatriation payments under Section 965, 163(j) interest adjustments, and even foreign exchange gains and losses.

Listen as our panel of SALT experts in foreign tax matters explains the latest development in state taxation of foreign income.



  1. Overview of state methods
  2. GILTI
  3. Section 250 deductions
  4. 163(j)
  5. Foreign exchange rate gains and losses
  6. State filing deadlines
  7. Other foreign income


The panel will cover these and other critical issues:

  • The latest state developments in taxing foreign income
  • Pending state legislation relative to the taxation of foreign income
  • Common state methods for taxing Section 951A income
  • How states treat 163(j) interest


Girmscheid, Katie
Katie Girmscheid, CPA
Managing Director, State and Local Tax

Ms. Girmscheid is a Senior Manager in BDO Chicago’s State and Local Tax Practice with over 9 years in public...  |  Read More

Lipin, Ilya
Ilya A. Lipin

Tax Principal, Atlantic Region State and Local Tax Practice Leader

Mr. Lipin provides clients with state tax advice in the area of multistate income taxes, sales and use taxes, tax...  |  Read More

Smith, Scott
Scott Smith

National Technical Practice Leader - State & Local Tax

Mr. Smith sets BDO's policies and positions on technical SALT issues, as well as thought leadership, brand...  |  Read More

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