State Taxation of Income From Foreign Affiliates After the Tax Reform
Multistate Treatment of GILTI, FDII, Section 250 Deductions and Other Tax Issues
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax specialists, advisers, and counsel with a deeper understanding of crucial multistate tax developments involving taxation of income derived from foreign affiliates and subsidiaries post Tax Cuts and Jobs Act (“TCJA”) of 2017. State taxation of GILTI varies depending on how states conform to TCJA and federal consolidated return regulations. For instance, some states do not conform to TCJA and thus do not include GILTI in their tax base and apportionment. Conforming states, however, may include GILTI in the tax base and tax it on the gross or net basis, exclude GILTI from the base, apply a subtraction modification, treat it similarly to Subpart F or dividend income. States treatment of including, excluding, or using a new method of apportioning GILTI provides additional compliance challenges. The panel will outline their perspectives and offer practical tools for strategic tax planning for tax managers and counsel to multistate companies.
- States treatment of foreign affiliates income before tax reform
- Repatriation transition tax
- GILTI and the Section 250 deduction
- FDII deduction
- Issues with apportionment factors
- Other state taxation issues
The panel will answer these and other essential questions:
- How are states and local jurisdictions treating GILTI and FDII?
- How are states calculating handling the relevant Section 250 deduction?
- From a state perspective, how does GILTI interact with other provisions in the TCJA?
- With GILTI in place, do states still need tax haven rules?
- Do states typically require worldwide combined, or water's edge, reporting of worldwide groups?
- Are states flexible with apportionment formula when income comes from overseas?
Evan M. Hamme
Pillsbury Winthrop Shaw Pittman
Mr. Hamme advises clients on all areas of state and local taxation, including income, franchise, excise, sales and use... | Read More
Mr. Hamme advises clients on all areas of state and local taxation, including income, franchise, excise, sales and use tax.Close
Ilya A. Lipin
Managing Director, State & Local Tax
Mr. Lipin provides clients with state tax advice in the area of multistate income taxes, sales and use taxes, tax... | Read More
Mr. Lipin provides clients with state tax advice in the area of multistate income taxes, sales and use taxes, tax controversy, compliance, and various SALT aspects that arise from M&A transactions.Close