If these other conformity issues are left unaddressed, they will will increase state tax liability for many business taxpayers.
|
|
- Dortha Miller
- 5 years ago
- Views:
Transcription
1 TO: FROM: SUBJECT: DATE: 5/15/18 Majority Leader John Flanagan Ken Pokalsky Additional TCJA Issues For many states, including New York, state-level business and personal income taxes are based on the federal tax code, so most states are considering options for respond2ing to the federal Tax Cut and Jobs Act of 2017, or TCJA. The recently adopted state budget included several provisions designed to avoid increased state-level tax liability for individual New York State taxpayers. And while the budget included several provisions that decouple from TCJA provisions that result in increased state-level tax increases for New York s business taxpayers, several significant issues still need to be addressed in the 2018 legislative session. If these other conformity issues are left unaddressed, they will will increase state tax liability for many business taxpayers. These include: - the TCJA imposes ongoing federal taxation of global intangible low tax income or GILTI, which is calculated based on a complex formula, and represents income earned abroad but not actually paid to a domestic parent company. Even so, this amount will be added to federal taxable income, and will flow through to state business tax returns. We are proposing an exemption for GILTI under the state and city business taxes. - the TCJA capped the deduction of business interest expenses at 30 percent of business income, but in exchange allowed a five year period where business could expense, rather than depreciate, most capital investments. New York is already decoupled from federal bonus depreciation, but New York business taxpayers will be subjected to increased state tax liability due to the interest deduction cap. New York should decouple from the federal cap - while the budget agreement confirmed and/or included an exemption for federal transition income under the state corporate franchise and insurance tax, and the NYC corporate tax, it did not address this issue for pass-thru entities (sub-s, partnerships, LLCs) that are shareholders in controlled foreign corporations. A similar exemption should be adopted for these unincorporated businesses under the state and NYC personal income taxes. - The influx of transition income and GILTI on state tax returns, and other TCJA provisions, could affect a taxpayer s status as a qualified New York manufacture, and therefore its eligibility for beneficial tax rates and real property tax credit. The state should decouple its definition of QNYA from federal changes, in order to avoid these adverse impacts. In general, the state had not projected or counted on any additional revenues from these provisions, so amendments adopted in the 2018 session should not impact the state s long term financial plans. However, these conformity issues will be seen as an economic competitiveness issue for New York and other states. Given the Administration and legislature s focus on avoiding unintended tax increases due to TCJA, these issues should also be addressed during the 2018 legislative session. The attached pages provide proposed legislation and addition information on each of these issues.
2 GILTI EXEMPTION BILL MEMO The final FY 2019 state budget adopted several measures to eliminate unintended increases in state-level income tax liability for New York s individual and business taxpayers resulting from recent federal reforms. Post-budget, the legislature needs to adopt several further technical amendments and reforms necessary to avoid similar unintended tax increases due to misalignment of federal and state tax laws. The 2017 federal Tax Cut and Jobs Act (TCJA) subjects a portion of undistributed earnings of foreign subsidiaries ( controlled foreign corporations, or CFCs) to ongoing federal taxation. Referred to as GILTI, or global intangible low-taxed income, this provision (IRC 951A) is intended to impose federal tax on income earned in low-tax foreign jurisdictions from intangible property, such as patents, copyrights, and trademarks. However, GILTI is actually a tax on the overall business income of foreign subsidiaries that is not distributed to the U.S. parent, and is calculated as a function of the taxpayer s foreign fixed assets, and not actual earnings from intangible assets in tax havens. At the federal level, a 50% deduction, plus tax credits for foreign taxes paid, have the effect of eliminating any additional federal tax liability on income attributed to nations with income tax rates at or above %. New York State s corporate franchise tax has always exempted this type of undistributed income of foreign subsidiaries. However, due to the way the federal law was drafted, GILTI is not included in New York s existing statutory exemption, therefore state tax law now requires that the federally taxable share of GILTI to be included in the tax returns of New York business taxpayers with ownership shares in CFCs. Without legislation to decouple from this federal provision, New York taxpayers will be subject to state-level tax on income that has not, and may never actually be, received by the New York taxpayer. In addition, the state tax levy is not reduced by the foreign tax credits allowed at the federal level, nor by the federal rate reductions. There are compelling reasons why New York should adopt legislation to exempt GILTI from state-level taxation under the state s corporate franchise and insurance taxes, and the New York City corporate tax: - Exemption is consistent with New York s long-standing policy to not tax the earnings of foreign subsidiaries. Moreover, in enacting federal reforms, Congress made clear that GILTI income was to be treated as subpart F (CFC) income in most circumstances, supporting like-treatment at the state level as well. - GILTI income was not included in federal returns prior to 2018, so it likewise would not have been reported to or taxed by New York State, which uses federal taxable income as the starting point for calculating state corporate franchise tax liability. Providing a state exemption would not impact the state s projected future tax receipts. - Imposing state taxes on foreign earnings would adversely impact New York s business climate, and change its long-standing tax policy. It will be contrary to the state s efforts to retain and attract multinational businesses, and will likely set New York apart from the majority of states. A number of other states already exempt GILTI from state-level taxation. - Under the state s corporate franchise tax, income is apportioned to New York based on the share of a taxpayer s total receipts earned within the state. However, the state s current apportionment statute does not specifically address GILTI. A lack of apportionment relief will both exacerbate the impact of state-level taxation of GILTI, will result in uncertain and complex compliance obligations for taxpayers, and would likely be the subject of legal challenge. - Federal and state-level taxation of GILTI could actually provide an unintended incentive to locate tangible business assets overseas, which would be a strategy to reduce the level of calculated GILTI income. Since GILTI provisions apply to tax years beginning on or after January 1, 2018, this issue needs to be addressed in the 2018 legislative session to avoid unintended, adverse impact on New York business taxpayers. Page 2 of 10
3 This decoupling legislation will support and enhance the Administration s focus on avoiding unintended tax increases for New York taxpayers due to federal reforms. GILTI decoupling was also included in the Senate s proposed revenue bill and budget resolution. Corporate Franchise Tax Amendments Section a(b) is amended to read as follows: (b) Exempt CFC income means (i) except to the extent described in subparagraph (ii) of this paragraph, the income required to be included in the taxpayer s federal gross income pursuant to subsection (a) of section 951 of the internal revenue code, received from a corporation that is conducting a unitary business with the taxpayer but is not included in a combined report with the taxpayer, and (ii) such income required to be included in the taxpayer s federal gross income pursuant to subsection (a) of such section 951 of the internal revenue code by reason of subsection (a) of section 965 of the internal revenue code, as adjusted by subsection (b) of section 965 of the internal revenue code, and without regard to subsection (c) of such section, received from a corporation that is not included in a combined report with the taxpayer, and (iii) such income required to be included in the taxpayer s federal gross income pursuant to subsection (a) of section 951A of the internal revenue code, without regard to the deduction under section 250 of the internal revenue code, received from a corporation that is not included in a combined report with the taxpayer, less, (iii) (iv) in the discretion of the commissioner, any interest deductions directly or indirectly attributable to that income. In lieu of subtracting from its exempt CFC income the amount of those interest deductions, the taxpayer may make a revocable election to reduce its total exempt CFC income by forty percent. If the taxpayer makes this election, the taxpayer must also make the elections provided for in paragraph (b) of subdivision six of this section and paragraph (c) of this subdivision. If the taxpayer subsequently revokes this election, the taxpayer must revoke the elections provided for in paragraph (b) of subdivision six of this section and paragraph (c) of this subdivision. A taxpayer which does not make this election because it has no exempt CFC income will not be precluded from making those other elections. The income described in subparagraph subparagraphs (ii) and (iii) of this paragraph shall not constitute investment income. Section 208.9(b) is amended by adding new subparagraph (25) to read as follows: (25) The amount of any federal deduction allowed pursuant to section 250(a)(1)(B)(i) of the internal revenue code. Effective Date: These amendment shall take effect immediately and shall apply to taxable years beginning on or after January 1, Page 3 of 10
4 Amendments to the Administrative Code of the City of New York: Section a(b) is amended to read as follows: (b) Exempt CFC income means (i) except to the extent described in subparagraph (ii) of this paragraph, the income required to be included in the taxpayer s federal gross income pursuant to subsection (a) of section 951 of the internal revenue code, received from a corporation that is conducting a unitary business with the taxpayer but is not included in a combined report with the taxpayer, and (ii) such income required to be included in the taxpayer s federal gross income pursuant to subsection (a) of such section 951 of the internal revenue code by reason of subsection (a) of section 965 of the internal revenue code, as adjusted by subsection (b) of section 965 of the internal revenue code, and without regard to subsection (c) of such section, received from a corporation that is not included in a combined report with the taxpayer, and (iii) such income required to be included in the taxpayer s federal gross income pursuant to subsection (a) of section 951A of the internal revenue code, without regard to the deduction under section 250 of the internal revenue code, received from a corporation that is not included in a combined report with the taxpayer, less, (iii) (iv) in the discretion of the commissioner of finance, any interest deductions directly or indirectly attributable to that income. In lieu of subtracting from its exempt CFC income the amount of those interest deductions, the taxpayer may make a revocable election to reduce its total exempt CFC income by forty percent. If the taxpayer makes this election, the taxpayer must also make the elections provided for in paragraph (b) of subdivision five of this section and paragraph (c) of this subdivision. If the taxpayer subsequently revokes this election, the taxpayer must revoke the elections provided for in paragraph (b) of subdivision five of this section and paragraph (c) of this subdivision. A taxpayer which does not make this election because it has no exempt CFC income will not be precluded from making those other elections. The income described in subparagraph subparagraphs (ii) and (iii) of this paragraph shall not constitute investment income. Section (b) is amended by adding new subparagraph (22) to read as follows: (22) The amount of any federal deduction allowed pursuant to section 250(a)(1)(B)(i) of the internal revenue code. Effective Date: These amendment shall take effect immediately and shall apply to taxable years beginning on or after January 1, Insurance Tax Amendments Proposed amendment to Tax Law 1503: Page 4 of 10
5 1503 (b) Modifications. In computing entire net income, the following modifications shall be made: (1) Entire net income shall not include: (T) To the extent not excluded from income pursuant to subparagraph (A) of paragraph one of this subdivision, the income required to be included in the taxpayer s federal gross income pursuant to subsection (a) of section 951A of the internal revenue code, without regard to the deduction under section 250 of the internal revenue code, that is generated by a corporation that is not included in a combined report with the taxpayer. (2) Entire net income shall be determined without the exclusion, deduction or credit of: (Y) The amount of the federal deduction allowed pursuant to subparagraph (B)(i) of paragraph one of subsection (a) of section 250 of the internal revenue code. Proposed amendment to Tax Law 1503(b)(2)(H) (H) in the discretion of the commissioner, any amount of interest directly or indirectly and any other amount directly attributable as a carrying charge or otherwise to subsidiary capital or to income, gains or losses from subsidiary capital, or to the income described in subparagraphs (S) and (T) of paragraph one of this subdivision; Effective Date: These amendment shall take effect immediately and shall apply to taxable years beginning on or after January 1, Page 5 of 10
6 PIT EXEMPTION FOR TRANSITION INCOME BILL MEMO - In general terms, the starting point for calculating New York s personal income tax (PIT) under Article 22 is a taxpayer s adjusted gross income (AGI). The federal Tax Cut and Jobs Act (TCJA) made numerous changes that expanded the Internal Revenue Code s (IRC) definition of income, and/or limited deductions and credits. Subsequently, the state s Executive Budget proposed, and the legislature approved, several measures to decouple from TCJA provisions in order to avoid significant state-level tax increase on for New York PIT taxpayers. However, significant concerns remain for some taxpayers. In particular, absent additional state action, certain undistributed foreign earnings would be included in state AGI for the owners of pass through businesses such as partnerships and LLCs, which pay tax on their business earnings at the individual level through the state s PIT. This so-called transition or deemed repatriated income was made taxable at the federal level under the newly adopted IRC 965. This provision requires taxpayers to pay a one-time federal tax on accumulated foreign profits regardless if such profits are actually repatriated to U.S. taxpayers. Importantly, this change in federal tax law was accompanied by a significant reduction in tax rates and other reforms that limited its impact at the federal level changes that do not flow through to state tax law. In addition, New York now exempts from tax this income for businesses set up as C-corps under Article 9A. We are proposing a legislative amendment to eliminate state tax liability for owners of unincorporated businesses due to these undistributed foreign earnings. Under this proposed change, these taxpayers state PIT liability would continue to be calculated in the same manner as it was prior to federal reforms, so that the state would see neither an increase nor decrease in tax revenues relative to pre-tcja levels. Moreover, once these foreign earnings were actually paid out to New York taxpayers, they would become fully taxable under the state s PIT, so this legislative change affects the timing, rather than just the taxability, of these foreign earnings. Our proposed language is presented below. Note, to effectuate the same outcome under the NYC income tax, a similar amendment would have to be made to NYC Administrative Code This proposed state change would automatically be reflected in the Yonkers city income tax surcharge, which is calculated as a percentage of state PIT liability. Proposed amendment to Tax Law 612: 612. New York adjusted gross income of a resident individual. (c) Modifications reducing federal adjusted gross income. There shall be subtracted from federal adjusted gross income: (44) 100% of the income required to be included in the taxpayer's federal gross income pursuant to subsection (a) of section 965 and subsection (a) of section 951A of the internal revenue code. # Page 6 of 10
7 DECOUPING FROM FEDERAL CAP ON DEDUCTION OF BUSINESS INTEREST BILL MEMO -- Under federal tax reform, the deduction for a business net interest expense will be limited to 30% of a taxpayer s federal adjusted taxable income (IRC section 163(j)), effective for the 2018 and future tax years (taxpayers with gross receipts under $25 million are exempt.) This cap was adopted by Congress along with bonus depreciation, which allows a taxpayer to immediately expense 100% of the cost of qualified property in the year the expense was incurred, effective for 2018 through 2023 (and phased down thru 2027). The reason for the federal limit on interest deductions was to prevent a double tax benefit based on property the cost of which is deducted in the year in which it is placed in service and not depreciated. Under current NYS tax law, this new federal cap on business interest deductions would flow through to businesses subject to the state s corporate franchise tax (Article 9A), as it is a component of federal taxable income which is the starting point for calculating Article 9A entire net income tax liability. However, New York State tax law is already decoupled from federal bonus depreciation, and the Cuomo administration is not proposing to adopt the federal immediate expensing regime. As a result, without technical amendments, New York taxpayers would be hit with increased tax liability due to the cap on interest deductions, while also being deprived of the state-level benefit of asset expensing. To address this one-sided outcome, the state should also decouple from the federal cap on business interest deductions for Article 9A taxpayers. Since Section 163 also provides that disallowed interest is carried forward and can be deducted in future tax years, to avoid a double-deduction, Article 9A amendments should also provide that any amount deducted from federal taxable income pursuant to a carry-forward of disallowed business interest should be added back to Article 9A entire net income. Without this amendment, businesses in New York would be subject to increased annual state tax liability of $45 million per year or more (according to NYS DTF estimates.) Proposed Amendments to NYC Corporate Tax of 2015: 208. Definitions. As used in this article: 9. The term "entire net income" means total net income from all sources, which shall be presumably the same as the entire taxable income, which, except as hereinafter provided in this subdivision (i) the taxpayer is required to report to the United States treasury Department... (a) Entire net income shall not include: (20) the amount disallowed as a deduction pursuant to clause (1) of subsection (j) of section 163 of the internal revenue code. (21) any amount deducted by reason of a carry forward of disallowed business interest pursuant to section 163(j)(2) of the internal revenue code. Page 7 of 10
8 Proposed Amendments to Insurance Tax: Computation of entire net income. (a) The entire net income of a taxpayer shall be its total net income from all sources which shall be presumably the same as... (b) Modifications. In computing entire net income, the following shall be made: modifications (1) Entire net income shall not include: (T) the amount disallowed as a deduction pursuant to clause (1) of subsection (j) of section 163 of the internal revenue code. (U) any amount deducted by reason of a carry forward of disallowed business interest pursuant to section 163(j)(2) of the internal revenue code. Proposed Amendments to NYC Corporate Tax of 2015: Definitions. 8. The term "entire net income" means total net income from all sources, which shall be presumably the same as the entire taxable income, which, except as hereafter provided in this subdivision, (a) Entire net income shall not include: (16) the amount disallowed as a deduction pursuant to clause (1) of subsection (j) of section 163 of the internal revenue code. (17) any amount deducted by reason of a carry forward of disallowed business interest pursuant to section 163(j)(2) of the internal revenue code. Page 8 of 10
9 QUALIFIED NEW YORK MANUFACTURERS BILL MEMO - Recent federal tax law changes could inadvertently disqualify manufacturers from beneficial treatment under New York s corporate franchise tax (Article 9A) and personal income tax (Article 22), with regard to the Article 9A manufacturers ENI tax rate, and eligibility for the manufacturer s real property credit under both articles. First, the inclusion of transition and/or GILTI income (new categories of foreign income addressed in federal tax reform) in a taxpayer s federal gross receipts could impact the principally engaged test to qualify as a manufacturer (the test is 50% of gross receipts from manufacturing activities, a calculation that could be altered by the inclusion of foreign-generated income from non-manufacturing activities.) Second, even if NYS remains decoupled with the recently enacted federal bonus depreciation set forth in IRC 168(k), its impact on a manufacturers federal adjusted property basis could likewise result in a taxpayer being disqualified as a NY manufacturer, by reducing their federal adjusted (after depreciation) basis of manufacturing property below applicable NYS thresholds. These inadvertent effects could be addresses with limited amendments to the Tax Law. There would be no impact on state revenues, as these changes simply preserve the intended effect of these Tax Law provisions as adopted by the state legislature. Our proposed amendments to Section 210 are presented below. Note, these changes will also impact the manufacturing RPT credit in Tax Law 210-B( 43) and 606(xx), both of which refer to the definition of qualified New York manufacturer in 210.1(a)(vi) Computation of tax. 1. The tax imposed by subdivision one of section two hundred nine of this chapter shall be: (a) Business income base. (vi) for taxable years beginning on or after January first, two thousand fourteen, the amount prescribed by this paragraph for a taxpayer which is a qualified New York manufacturer, shall be computed at the rate of zero percent of the taxpayer's business income base. The term "manufacturer" shall mean a taxpayer which during the taxable year is principally engaged in the production of goods by manufacturing, processing, assembling, refining, mining, extracting, farming, agriculture, horticulture, floriculture, viticulture or commercial fishing. However, the generation and distribution of electricity, the distribution of natural gas, and the production of steam associated with the generation of electricity shall not be qualifying activities for a manufacturer under this subparagraph. Moreover, in the case of a combined report, the combined group shall be considered a "manufacturer" for purposes of this subparagraph only if the combined group during the taxable year is principally engaged in the activities set forth in this paragraph, or any combination thereof. A taxpayer or, in the case of a combined report, a combined group shall be "principally engaged" in activities described above if, during the taxable year, more than fifty percent of the gross receipts (excluding any receipts that would be included pursuant to subsection (a) of section 965 and subsection (a) of section 951A of the internal revenue code) of the taxpayer or combined group, respectively, are derived from receipts from the sale of goods produced by such activities. In computing a combined group's gross receipts, intercorporate receipts shall be eliminated. A "qualified New York manufacturer" is a manufacturer which has property in New York which is Page 9 of 10
10 described in clause (A) of subparagraph (i) of paragraph (b) of subdivision one of section two hundred ten-b of this article and either (I) the adjusted basis of such property for federal state income tax purposes at the close of the taxable year is at least one million dollars or (II) all of its real and personal property is located in New York. A taxpayer or, in the case of a combined report, a combined group, that does not satisfy the principally engaged test may be a qualified New York manufacturer if the taxpayer or the combined group employs during the taxable year at least two thousand five hundred employees in manufacturing in New York and the taxpayer or the combined group has property in the state used in manufacturing, the adjusted basis of which for federal state income tax purposes at the close of the taxable year is at least one hundred million dollars. Page 10 of 10
NEW YORK CORPORATE TAX REFORM
I. Overview A. Goals NEW YORK CORPORATE TAX REFORM Jeffrey S. Reed Chair, State and Local Tax Department Kilpatrick Townsend LLP (212) 775-8792 jsreed@kilpatricktownsend.com 1. Modernization. In the words
More informationTreatment of Section 78 Gross-Up Amounts Relating to Section 960(b) Foreign Income Taxes
Treatment of Section 78 Gross-Up Amounts Relating to Section 960(b) Foreign Income Taxes I. Overview In 2017, Congress significantly revised the structure of the U.S. international tax system as part of
More informationTax Cuts and Job Act of 2017
Tax Cuts and Job of 2017 Prepared by Office of Legislative Council and Joint Fiscal Office Enacted December 22, 2017. Makes major changes to three federal taxes: Personal Income, Corporate Income, and
More informationPayroll Tax. Key elements of this new legislation:
Payroll Tax Governor Cuomo proposed employer compensation expense tax (ECET), or payroll tax, was adopted as part of the state s FY 2019 budget (See S.7509-C, Part MM Final bill text is attached). This
More informationFederal Tax Reform How Have the States Reacted So Far?
Federal Tax Reform How Have the States Reacted So Far? 2018 MSATA Annual Meeting Kansas City, Missouri August 21, 2018 Karl Frieden, COST Helen Hecht, MTC Alysse McLoughlin, McDermott, Will & Emery Agenda
More informationUS tax thought leadership December 18, 2017
US tax thought leadership December 18, 2017 This thought leadership compares the conference committee report released on December 15, 2017 with the existing tax provisions and its impact on US corporate
More informationSENATE, No. 786 STATE OF NEW JERSEY. 218th LEGISLATURE PRE-FILED FOR INTRODUCTION IN THE 2018 SESSION
SENATE, No. STATE OF NEW JERSEY th LEGISLATURE PRE-FILED FOR INTRODUCTION IN THE 0 SESSION Sponsored by: Senator PAUL A. SARLO District (Bergen and Passaic) Co-Sponsored by: Senators Greenstein and Ruiz
More informationState responses to tax reform
State responses to tax reform Federal tax reform- an overview H.R. 1 signed into law December 22, 2017 Included elements of the House and Senate versions of the bills - Not many surprises in conference
More informationTWIST-Q Summary of developments First Quarter 2019
TWIST-Q Summary of developments First Quarter 2019 This checklist includes developments for Quarter 1 of 2019 that have occurred prior to the date of publication. Please note that certain Quarter 1 items
More informationA BILL IN THE COUNCIL OF DISTRICT OF COLUMBIA
A BILL IN THE COUNCIL OF DISTRICT OF COLUMBIA To amend Title 47, Chapter 18 of the District of Columbia Official Code by adding thereto new sections, designated 47-1805.02A, 47-1810.04, 47-1810.05, 47-1810.06,
More informationUS Tax Reform: Impact on Private Funds
2018 INVESTMENT MANAGEMENT CONFERENCE CHICAGO US Tax Reform: Impact on Private Funds Adam J. Tejeda, New York Frank W. Dworak, Orange County January 31, 2018 Copyright 2018 by K&L Gates LLP. All rights
More informationInternal Revenue Code Section 199(c)(4) Income attributable to domestic production activities
CLICK HERE to return to the home page Internal Revenue Code Section 199(c)(4) Income attributable to domestic production activities (a) Allowance of deduction. There shall be allowed as a deduction an
More informationS Corporation Association Technical Comments & Questions
S Corporation Association Technical Comments & Questions Priorities Section 199A and Grouping: The new law fails to specify what constitutes a trade or business for purposes of this rule, though it does
More informationH 7245 S T A T E O F R H O D E I S L A N D
======== LC0001 ======== 01 -- H S T A T E O F R H O D E I S L A N D IN GENERAL ASSEMBLY JANUARY SESSION, A.D. 01 A N A C T RELATING TO TAXATION -- PERSONAL INCOME TAX Introduced By: Representatives Guthrie,
More informationState Tax Impact of the Transition Tax and GILTI
Journal of Multistate Taxation and Incentives (Thomson Reuters/Tax & Accounting) Volume 28, Number 3, June 2018 SHOP TALK State Tax Impact of the Transition Tax and GILTI By JEFFREY S. REED JEFFREY S.
More informationTECHNICAL EXPLANATION OF THE SENATE COMMITTEE ON FINANCE CHAIRMAN S STAFF DISCUSSION DRAFT OF PROVISIONS TO REFORM INTERNATIONAL BUSINESS TAXATION
TECHNICAL EXPLANATION OF THE SENATE COMMITTEE ON FINANCE CHAIRMAN S STAFF DISCUSSION DRAFT OF PROVISIONS TO REFORM INTERNATIONAL BUSINESS TAXATION Prepared by the Staff of the JOINT COMMITTEE ON TAXATION
More informationSection 199(a) of the Tax Reform Act of 2017 and 707 of 26 U.S. Code
Section 199(a) of the Tax Reform Act of 2017 and 707 of 26 U.S. Code AT THE FIRST SESSION Begun and held at the City of Washington on Tuesday, the third day of January two thousand and seventeen To provide
More informationFeedback for REG ( Transition Tax) as of 10/3/2018 SECTION TITLE ISSUE RECOMMENDATION ADDITIONAL EXPLANATION /QUERIES
Feedback for REG-104226-18 ( 965 1 Transition Tax) as of 10/3/2018 PROPOSED REGS Preamble Pages 63-64 Double counting for November 2017 distributions to the United States from 11/30 year end deferred foreign
More informationGENERAL ASSEMBLY OF NORTH CAROLINA SESSION 2007 S 1 SENATE BILL 244* Short Title: Modernize Corporate Income Tax Filing.
GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 0 S SENATE BILL * Short Title: Modernize Corporate Income Tax Filing. Sponsors: Referred to: Finance. (Public) Senators Hoyle, Clodfelter, Dalton, Hartsell, Kerr;
More informationOVERVIEW OF INCOME AND FRANCHISE TAX AND APPORTIONMENT. Senate Finance, March 10, 2015 Jonathan Tart, Fiscal Research Division
OVERVIEW OF INCOME AND FRANCHISE TAX AND APPORTIONMENT Senate Finance, March 10, 2015 Jonathan Tart, Fiscal Research Division Personal Income Tax Calculation 2013 Legislation eliminated many deductions
More informationH.F Contents. Bill Summary. As amended by H2125DE1. Alexandra Haigler Christopher Kleman Jared Swanson Pat Dalton Sean Williams
Bill Summary Subject Authors Analyst Omnibus Tax Bill Marquart Alexandra Haigler Christopher Kleman Jared Swanson Pat Dalton Sean Williams Date April 8, 2019 Contents Article 1: Federal Conformity... 2
More informationCOUNSEL ESS/NP/JW/JP/RER/GC SCS3982A-3
1.1 Senator... moves to amend S.F. No. 3982 as follows: 1.2 Delete everything after the enacting clause and insert: 1.3 "ARTICLE 1 1.4 FEDERAL TAX CONFORMITY 1.5 Section 1. Minnesota Statutes 2017 Supplement,
More informationS 2190 S T A T E O F R H O D E I S L A N D
======== LC001 ======== 01 -- S S T A T E O F R H O D E I S L A N D IN GENERAL ASSEMBLY JANUARY SESSION, A.D. 01 A N A C T RELATING TO TAXATION - RENEWABLE ENERGY TAX CREDIT Introduced By: Senators P Fogarty,
More informationUS tax thought leadership November 16, 2017
US tax thought leadership November 16, 2017 This thought leadership deals with the tax reforms proposed by the House Ways and Means Committee and the Senate Finance Committee and its impact on the US corporations.
More informationNEW YORK STATE BAR ASSOCIATION TAX SECTION. Annual Meeting. State and Local Tax Implications of Federal Tax Reform.
NEW YORK STATE BAR ASSOCIATION TAX SECTION Annual Meeting State and Local Tax Implications of Federal Tax Reform January 23, 2018 Chair: Irwin M. Slomka, Morrison & Foerster LLP, New York City Joshua E.
More informationLegislative Information - LBDC
Page 1 of 9 PART A Section 1. Paragraph (a) of subdivision 6 of section 425 of the real property tax law, as amended by chapter 6 of the laws of 2010, and as further amended by subdivision (b) of section
More informationU.S. Tax Reform International Corporate Tax Provisions: The Good, the Bad and the Extremely Complex
U.S. Tax Reform International Corporate Tax Provisions: The Good, the Bad and the Extremely Complex On December 22, 2017, President Trump signed into law the 2017 U.S. tax reform bill An Act to provide
More informationTax Section. Memorandum re Recommended Technical Corrections to 2014 New York State Corporate Tax Reform Legislation.
Tax Section Memorandum re Recommended Technical Corrections to 2014 New York State Corporate Tax Reform Legislation. Tax #3 September 5, 2014 Introduction Memorandum re Recommended Technical Corrections
More informationTax Cuts & Jobs Act: Considerations for Funds
A LERT M EM OR A N D UM Tax Cuts & Jobs Act: Considerations for Funds January 25, 2018 On December 22, 2017, the President signed into law the 2017 U.S. tax reform bill formerly known as the Tax Cuts &
More informationNorth Carolina Draft Tax Legislation Released
North Carolina Draft Tax Legislation Released 04.17.2018 By William W. Nelson PROFESSIONALS William W. Nelson On April 11, 2018, the General Assembly s Revenue Laws Study Committee released a draft tax
More informationU.S. Tax Legislation Corporate and International Provisions. Corporate Law Provisions
U.S. Tax Legislation Corporate and International Provisions On December 20, 2017, Congress enacted comprehensive tax legislation (the Act ). This memorandum highlights some of the important provisions
More informationThe State Taxation of Foreign Source Income: Planning, Compliance, and Constitutional Challenges Post-Federal Tax Reform
The State Taxation of Foreign Source Income: Planning, Compliance, and Constitutional Challenges Post-Federal Tax Reform PRESENTERS: ALYSSE MCLOUGHLIN, MCDERMOTT WILL & EMERY, NEW YORK, NY JEFFREY VESELY,
More informationTop Questions About the New Tax Law
Top Questions About the New Tax Law The American workforce is stressed out and finances play a major role. Many workers say they re living paycheckto-paycheck, and the routine is stressing them out so
More informationRulings of the Tax Commissioner
Rulings of the Tax Commissioner Tax Type: Individual Income Tax Brief Description: Guidelines for Pass Through Entity Withholding Topics: Pass Through Entities Persons Subject to Tax Withholding of Tax
More informationNYS Corporate Tax Reform Overview. Stephen J. Sprada, CPA
NYS Corporate Tax Reform Overview Stephen J. Sprada, CPA Stephen.Sprada@tax.ny.gov Reasons for Reform Structure was outdated Structure created disincentives to doing business and expanding in New York
More informationSUMMARY: This document contains temporary regulations that address transactions
This document is scheduled to be published in the Federal Register on 04/08/2016 and available online at http://federalregister.gov/a/2016-07300, and on FDsys.gov [4830-01-p] DEPARTMENT OF THE TREASURY
More informationInternal Revenue Code Section 172(c) Net operating loss deduction.
Note: This document has been updated to reflect amendments by the TCJA, Pub. L. No. 115-97. CLICK HERE to return to the home page Internal Revenue Code Section 172(c) Net operating loss deduction. (a)
More informationState Tax Matters The power of knowing. February 15, In this issue:
State Tax Matters The power of knowing. In this issue: Idaho: New Law Generally Updates State Conformity to Internal Revenue Code, Revises NOL Computation... 2 Idaho: Revised Temporary Administrative Rule
More informationThe 2019 National Multistate Tax Symposium State tax reboot The age of Multistate. February 6-8, 2019
The 2019 National Multistate Tax Symposium State tax reboot The age of Multistate February 6-8, 2019 State treatment of federal Tax Cuts and Jobs Act s foreign income and GILTI Susan Courson-Smith, Pfizer
More information78th OREGON LEGISLATIVE ASSEMBLY Regular Session. House Bill 2076
th OREGON LEGISLATIVE ASSEMBLY--0 Regular Session House Bill 0 Introduced and printed pursuant to House Rule.00. Presession filed (at the request of House Interim Committee on Revenue) SUMMARY The following
More informationDon t Forget the SALT: State and Local Tax Implications of Federal Tax Reform
Tax Implications of Federal Tax Reform By Harley Duncan, Dan De Jong, Marianne Evans, and Sarah McGahan 2018 is a new year and with it comes new challenges and opportunities for U.S. taxpayers. On December
More informationUS tax thought leadership November 22, 2017
US tax thought leadership November 22, 2017 This thought leadership provides an update on the tax reforms proposed by the House Ways and Means Committee and the Senate Finance Committee and their impact
More informationThe Investment Lawyer
The Investment Lawyer Covering Legal and Regulatory Issues of Asset Management VOL. 25, NO. 3 MARCH 2018 REGULATORY MONITOR Private Funds Update By Frank Dworak and Adam Tejeda The Tax Cuts and Jobs Act
More informationFederal Tax Reform Impact on 2019 Legislative Sessions: GILTI
Federal Tax Reform Impact on 2019 Legislative Sessions: GILTI Executive Committee Task Force on State and Local Taxation Scottsdale, Arizona November 17, 2018 Karl Frieden, COST Deborah Bierbaum, AT&T
More informationGENERAL ASSEMBLY OF NORTH CAROLINA SESSION 1993 S 1 SENATE BILL May 25, 1994
GENERAL ASSEMBLY OF NORTH CAROLINA SESSION S SENATE BILL Short Title: Repeal Intangibles Tax. Sponsors: Senators Kerr; and Albertson. Referred to: Finance. (Public) May, 0 0 A BILL TO BE ENTITLED AN ACT
More informationState Tax Implications of Federal Tax Reform
State Tax Implications of Federal Tax Reform Todd Lard, Partner Todd Betor, Associate 2018 (US) LLP All Rights Reserved. This communication is for general informational purposes only and is not intended
More informationInternal Revenue Code Section 164(b)(6) (flush language) Taxes
Note: This document has been updated to reflect amendments by the TCJA, Pub. L. No. 115-97. CLICK HERE to return to the home page Internal Revenue Code Section 164(b)(6) (flush language) Taxes (a) General
More informationNew Tax Law: International
New Tax Law: International Provisions and Observations April 18, 2018 kpmg.com 1 In the context of international tax, the Public Law 115-97 (popularly, if not officially, referred to as the Tax Cuts and
More informationTax Cuts and Jobs Act of 2017 International Tax Provisions and Provisions Affecting Exempt Organizations
Tax Cuts and Jobs Act of 2017 International Tax Provisions and Provisions Affecting Exempt Organizations By Robert E. Ward* Robert E. Ward outlines the international tax provisions and provisions affecting
More informationChanges to the New Jersey Corporation Business Tax
Changes to the New Jersey Corporation Business Tax TB-84 - Issued December 10, 2018 Tax: Corporation Business Tax P.L. 2018, c. 48, signed into law on July 1, 2018, and P.L. 2018, c. 131, signed into law
More informationFeedback for Notice (Repatriation) as of 1/31/2018
Feedback for Notice 2018-07 (Repatriation) as of 1/31/2018 NOTICE 2018-07, Section 3.01 Determination of Aggregate Foreign Cash Position How will intercompany dividends be calculated? Section 3.01(b) Treatment
More information2017 Tax Reform: Checkpoint Special Study on foreign income, foreign persons tax changes in the "Tax Cuts and Jobs Act"
2017 Tax Reform: Checkpoint Special Study on foreign income, foreign persons tax changes in the "Tax Cuts and Jobs Act" On December 15, the Conference Committee-having reconciled and merged the differing
More informationSTATE OF MINNESOTA DEPARTMENT OF REVENUE
This document is made available electronically by the Minnesota Legislative Reference Library as part of an ongoing digital archiving project. http://www.leg.state.mn.us/lrl/sonar/sonar.asp STATE OF MINNESOTA
More informationF.Y F.Y F.Y F.Y.
April 16, 2018 State Taxes Only See Separate Analysis for Property Tax Provisions Governor s Tax Bill State Tax Provisions Only DOR Administrative Costs/Savings Yes X No Department of Revenue Fund Impact
More informationArticle 1 Section moves to amend H.F. No as follows: 1.2 Delete everything after the enacting clause and insert: 1.
1.1... moves to amend H.F. No. 4385 as follows: 1.2 Delete everything after the enacting clause and insert: 1.3 "ARTICLE 1 1.4 FEDERAL TAX CONFORMITY 1.5 Section 1. Minnesota Statutes 2017 Supplement,
More informationThe Omnibus Property Tax Relief and Reform Act
The Omnibus Property Tax Relief and Reform Act As part his proposed Education, Labor, and Family Assistance Article VII budget bill (S-A/A1- A, Governor David A. Paterson has proposed repealing the Middle
More informationCorporation Income and Franchise Taxes Statutes and Regulations
Corporation Income and Franchise Taxes Statutes and Regulations R-6600 January 2003 A publication of the Louisiana Department of Revenue This public document was published at a total cost of $17,300. Five
More informationClient Alert February 14, 2019
Tax News and Developments North America Client Alert February 14, 2019 Voluminous Proposed Regulations Interpret Section 163(j) Overview On November 26, 2018, the Treasury and IRS released proposed regulations
More informationAmnesty: Texas Comptroller Reminds that Tax Amnesty Program will Run from May 1 to June 29; Provides for Potential Waiver of Penalties and Interest
State Tax Matters The power of knowing. In this issue: Amnesty: Texas Comptroller Reminds that Tax Amnesty Program will Run from May 1 to June 29; Provides for Potential Waiver of Penalties and Interest...
More informationFederal Tax Changes Rocking the SALT Landscape. TEI New Jersey Chapter November 16, 2018
Federal Tax Changes Rocking the SALT Landscape TEI New Jersey Chapter November 16, 2018 Carley A. Roberts Partner Marc A. Simonetti Partner Agenda Federal Tax Changes Rocking the SALT Landscape Repatriation
More information5.5 Ways To Remove GILTI From Your State Tax Base
Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com 5.5 Ways To Remove GILTI From Your State
More informationFederal Tax Reform & the States. The Big Picture. Status Update in the States
Federal Tax Reform & the States The Big Picture Status Update in the States Introductions Panelists Liz Malm Nathan Rigney Steve Kranz Karl Frieden MultiState Associates H&R Block McDermott WIll & Emery
More informationAnnual Update on California s Manufacturing Tax Incentives
Special Report for Cal-Tax Online December 1999 Annual Update on California s Manufacturing Tax Incentives by Chris Micheli I. INTRODUCTION The purpose of this article is to provide another annual update
More informationTax Cuts & Jobs Act: Considerations for M&A
A LERT M EM OR A N D UM Tax Cuts & Jobs Act: Considerations for M&A January 17, 2018 On December 22, 2017, the President signed into law the 2017 U.S. tax reform bill formerly known as the Tax Cuts & Jobs
More information62 ASSOCIATION OF CORPORATE COUNSEL
62 ASSOCIATION OF CORPORATE COUNSEL CHEAT SHEET Foreign corporate earnings. Under the recently created Tax Cuts and Jobs Act, taxation and participation exemption of foreign corporate earnings have significantly
More informationState Tax After TCJA: Treatment Of International Income
Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com State Tax After TCJA: Treatment Of International
More informationTax Cuts & Jobs Act: Considerations for M&A
A LERT M EM OR A N D UM Tax Cuts & Jobs Act: Considerations for M&A January 12, 2018 On December 22, 2017, the President signed into law the 2017 U.S. tax reform bill formerly known as the Tax Cuts & Jobs
More informationTax Reform: Taxation of Income of Controlled Foreign Corporations
Reproduced with permission from Daily Tax Report, 14 DTR S-15, 1/22/18. Copyright 2018 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com CFCs Lowell D. Yoder, David G. Noren, and
More informationNEW YORK. chart maximum. NEW YORK tax rates. Maximum Tax Rates State or City
state tax issues New York, New Jersey, Connecticut and Pennsylvania all tax most of the income subject to federal income tax, but all four states either limit or exclude the itemized deductions you claimed
More informationCHAPTER 2 BUSINESS FRANCHISE TAX. By David L. Phillips
CHAPTER 2 BUSINESS FRANCHISE TAX By David L. Phillips David L. Phillips is an executive director in charge of tax practice for the Charleston, West Virginia office of Ernst & Young. He was a special advisor
More information17 NCAC 05B.1105 is readopted with changes pursuant to G.S. 150B-21.3A(c)(2)g without notice pursuant to G.S. 150B- 1(d)(4) as follows:
0 NCAC 0B.0 is readopted with changes pursuant to G.S. 0B-.A(c)()g without notice pursuant to G.S. 0B- (d)() as follows: NCAC 0B.0 INVESTMENT IN SUBSIDIARY For purposes of G.S. 0-, the capital stock, surplus,
More information[First Reprint] ASSEMBLY, No STATE OF NEW JERSEY. 218th LEGISLATURE INTRODUCED JUNE 21, 2018
[First Reprint] ASSEMBLY, No. STATE OF NEW JERSEY th LEGISLATURE INTRODUCED JUNE, 0 Sponsored by: Assemblywoman ELIANA PINTOR MARIN District (Essex) Senator STEPHEN M. SWEENEY District (Cumberland, Gloucester
More informationSTATE OF OKLAHOMA. 2nd Extraordinary Session of the 56th Legislature (2018) HOUSE BILL 1037 By: Wallace of the House AS INTRODUCED
STATE OF OKLAHOMA 2nd Extraordinary Session of the 56th Legislature (2018) HOUSE BILL 1037 By: Wallace of the House and Thompson of the Senate AS INTRODUCED An Act relating to revenue and taxation; amending
More informationChanges Abound in New Tax Bill for Multinational Companies
News Changes Abound in New Tax Bill for Multinational Companies 01.08.2018 Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the Act ), deal with the taxation of
More information"ARTICLE 1 INCOME AND FRANCHISE TAXES
1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 1.10 1.11 1.12 1.13 1.14 1.15 1.16 1.17 1.18 1.19 1.20 1.21 1.22 1.23 1.24 1.25... moves to amend H.F. No. 848 as follows: Delete everything after the enacting clause
More informationWhat Nexus Standard Would the Bill Require to Impose an Income Tax?
All States Income Tax Nexus Legislation Introduced in Congress November 2018 A bill introduced in the U.S. House of Representatives would: establish a federal physical presence nexus standard for state
More informationState Implications of Federal Tax Reform. National Conference of State Legislatures January 2018
State Implications of Federal Tax Reform National Conference of State Legislatures January 2018 Notices The following information is not intended to be written advice concerning one or more Federal tax
More informationCorporate Taxation Spring 2018 Prof. Bogdanski. Statutory Supplement for Public Law (Tax Cuts and Jobs Act of 2017) Contents
Corporate Taxation Spring 2018 Prof. Bogdanski Statutory Supplement for Public Law 115-97 (Tax Cuts and Jobs Act of 2017) Code Section affected Contents Code changes, page Legislative history, page 1 2
More informationRelated Member Interest Expenses and Costs; and Intangible Expenses and Costs.
560-7-3-.05 Related Member Interest Expenses and Costs; and Intangible Expenses and Costs. (1) Purpose. The purpose of this regulation is to provide guidance with regard to the administration of O.C.G.A.
More informationNC General Statutes - Chapter 105 Article 3 1
Article 3. Franchise Tax. 105-114. Nature of taxes; definitions. (a) Repealed by Session Laws 2017-204, s. 1.1, effective August 11, 2017. (a1) Scope. The tax levied in this Article upon corporations is
More information79th OREGON LEGISLATIVE ASSEMBLY Regular Session. Enrolled
79th OREGON LEGISLATIVE ASSEMBLY--2017 Regular Session Enrolled House Bill 2275 Introduced and printed pursuant to House Rule 12.00. Presession filed (at the request of Governor Kate Brown for Department
More informationMANAGING INTERNATIONAL TAX ISSUES
MANAGING INTERNATIONAL TAX ISSUES Starting A Business Retirement Strategies Operating A Business Marriage Investing Tax Smart Estate Planning Ending A Business Off to School Divorce And Separation Travel
More informationState implications of federal tax reform the international provisions
State implications of federal tax reform the international provisions Disclaimer EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited,
More informationFederal Tax Reform Idaho Impact
Federal Tax Reform Idaho Impact The potential effect of federal tax reform for Idaho On December 22, 2017, the President signed into law the Tax Cuts and Jobs Act. This legislation includes provisions
More informationASSEMBLY BILL No. 1341
california legislature 2017 18 regular session ASSEMBLY BILL No. 1341 Introduced by Assembly Member Calderon February 17, 2017 An act to add Section 44258.6 to the Health and Safety Code, and to amend
More informationAs Introduced. 132nd General Assembly Regular Session H. B. No
132nd General Assembly Regular Session H. B. No. 751 2017-2018 Representative Smith, T. A B I L L To amend sections 5747.01 and 5747.06 of the Revised Code to authorize an income tax deduction for volunteer
More informationThank you for the opportunity to comment on the Department s draft Article 9-A and Article 32 regulations regarding combined reports.
TO: John W. Bartlett, Director of Regulations, NYS Department of Taxation and Finance FROM: Kenneth J. Pokalsky SUBJECT: Draft Combined Report Regulation DATE: 11/7/08 Thank you for the opportunity to
More informationNC General Statutes - Chapter 105 Article 4 1
Article 4. Income Tax. Part 1. Corporation Income Tax. 105-130. Short title. This Part of the income tax Article shall be known and may be cited as the Corporation Income Tax Act. (1939, c. 158, s. 300;
More informationTax Reform ASC 740 Considerations: House Bill and Senate Finance Committee Proposal
: House Bill and Senate Finance Committee Proposal ASC 740 Ready for Tax Reform? The corporate tax provisions of the Tax Cuts and Jobs Act latest developments The Tax Cuts and Jobs Act ( TCJA ) continues
More informationInternal Revenue Code Section 199A(a) Qualified Business Income
CLICK HERE to return to the home page Internal Revenue Code Section 199A(a) Qualified Business Income (a) IN GENERAL. In the case of a taxpayer other than a corporation, there shall be allowed as a deduction
More informationTAX REFORM CODE OF PERSONAL INCOME TAX AND STRATEGIC DEVELOPMENT AREAS Act of Nov. 20, 2006, P.L. 1385, No. 151 Cl. 72
TAX REFORM CODE OF 1971 - PERSONAL INCOME TAX AND STRATEGIC DEVELOPMENT AREAS Act of Nov. 20, 2006, P.L. 1385, No. 151 Cl. 72 Session of 2006 No. 2006-151 SB 854 AN ACT Amending the act of March 4, 1971
More informationNew Entity-Level Tax. Overview
SALT Alert! 2018-05: Connecticut: Bill Adopting a New Partnership Tax and Addressing Aspects of Tax Reform Passes Legislature; Heads to Governor for Signature Connecticut Senate Bill 11, which was passed
More informationTechnical Line. A closer look at accounting for the effects of the Tax Cuts and Jobs Act. What you need to know. Overview
No. 2018-02 Updated 10 January 2018 Technical Line A closer look at accounting for the effects of the Tax Cuts and Jobs Act In this issue: Overview... 1 Summary of key provisions of the Tax Cuts and Jobs
More informationAs Introduced. 132nd General Assembly Regular Session S. B. No Senator Jordan A B I L L
132nd General Assembly Regular Session S. B. No. 176 2017-2018 Senator Jordan A B I L L To amend sections 709.023, 718.01, 718.02, 718.03, 718.04, 718.05, and 718.16 and to repeal sections 718.011 and
More information79th OREGON LEGISLATIVE ASSEMBLY Regular Session. Senate Bill 1527
th OREGON LEGISLATIVE ASSEMBLY--0 Regular Session Senate Bill Printed pursuant to Senate Interim Rule. by order of the President of the Senate in conformance with presession filing rules, indicating neither
More information79th OREGON LEGISLATIVE ASSEMBLY Regular Session
th OREGON LEGISLATIVE ASSEMBLY-- Regular Session House Bill Introduced and printed pursuant to House Rule.00. Presession filed (at the request of Governor Kate Brown for Department of Revenue) SUMMARY
More informationTax Cuts and Jobs Act of 2017 An Update LEGISLATIVE REVENUE OFFICE JANUARY 2018
Tax Cuts and Jobs Act of 2017 An Update LEGISLATIVE REVENUE OFFICE JANUARY 2018 1 Presentation Outline Summary of Provisions Individual Provisions Tax rates Deductions Other Preliminary revenue impacts
More informationState Implications of Federal Tax Reform. National Conference of State Legislatures State Taxation Task Force November 2017
State Implications of Federal Tax Reform National Conference of State Legislatures State Taxation Task Force November 2017 Notices The following information is not intended to be written advice concerning
More informationInternal Revenue Code Section 197 Amortization of goodwill and certain other intangibles
Internal Revenue Code Section 197 Amortization of goodwill and certain other intangibles CLICK HERE to return to the home page (a) General rule. A taxpayer shall be entitled to an amortization deduction
More informationTransition Tax DEEMED REPATRIATION OVERVIEW
Transition Tax DEEMED REPATRIATION OVERVIEW Basic Framework A 10% U.S. shareholder (a US SH ) of a specified foreign corporation ( SFC ) must recognize its pro rata share of the SFC s post-1986 accumulated
More information