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State Taxation of Foreign Income: Section 163(j), GILTI, Section 250 Deduction, Subpart F

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, July 13, 2023

Recorded event now available

or call 1-800-926-7926

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 and the corresponding Section 250 deduction and 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.

In addition to Section 951A income, there are significant differences in 163(j) interest adjustments and even foreign exchange gains and losses. 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.

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


Dagarag, Raymund
Raymund Dagarag

Tax Partner STS-SALT

Mr. Dagarag has over 25 years of experience addressing multijurisdiction state & local tax issues for businesses...  |  Read More

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

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