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State Taxes GILTI tax

Fenwick & West LLP

Notice 2023-63 Proposes Comprehensive Guidance on the New R&D Capitalization Requirements

Fenwick & West LLP on

Released on September 8, 2023, IRS Notice 2023-63 provides wide-ranging and potentially controversial guidance on the capitalization and amortization of research and experimentation expenses under section 174....more

Blank Rome LLP

New Jersey Makes Substantial Changes to the Corporation Business Tax

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On July 3, 2023, New Jersey Governor Phil Murphy signed into law S.B. 3737 / A.B. 5323 (the “Bill”), which makes significant changes to the Corporation Business Tax (“CBT”). Some of the most noteworthy changes are summarized...more

McDermott Will & Emery

Supreme Court Takes Up Constitutional Challenge to Section 965 Transition Tax

On June 26, 2023, the Supreme Court of the United States agreed to hear a rare challenge under the Sixteenth Amendment and Tax Clauses to Section 965 of the tax code. In Moore v. United States, the justices will consider...more

Eversheds Sutherland (US) LLP

Tax ins and outs of the New York State budget: Legislative amendments made to Governor Hochul’s Fiscal Year 2024 Executive Budget

On March 15, 2023, the two houses of the New York State Legislature released their respective amendments (Senate Bills S.4008 and S.4009, Assembly Bills A.3008 and A.3009, collectively the Amendments) to New York Governor...more

Williams Mullen

Virginia Department of Taxation Releases Initial Guidance on New Pass-Through Entity Election, Including Important Details for...

Williams Mullen on

During the 2022 General Assembly Session, legislation was enacted that allows a qualifying pass-through entity (PTE) to make an annual election for Taxable Years 2021 through 2025 to pay income tax at a rate of 5.75% at the...more

BakerHostetler

[Podcast] Dodging the California Foreign Tax Bullet - AB 71

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California Assembly Bill 71 would have made major changes to how California taxes foreign income, including a thinly-veiled attempt to get multinationals to elect worldwide combination. It looks like the bill will not pass...more

Gould + Ratner LLP

Pending Changes to Illinois Tax Laws Include SALT Workaround

Gould + Ratner LLP on

Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more

McDermott Will & Emery

[Webinar] Tax in the City®: San Francisco - May 18th, 1:00 pm - 2:30 pm PDT

Please join us for our inaugural Tax in the City® in San Francisco—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and confidential setting. Our...more

Bradley Arant Boult Cummings LLP

ADOR Issues Guidance on New PTE Tax Election and Consequences of Decoupling from GILTI and IRC §118(b)(2)

At the urging of the Alabama Society of CPAs and other groups, the Alabama Department of Revenue (ADOR) recently issued preliminary guidance on (a) how the new pass-through entity (PTE) tax election interacts with the...more

Eversheds Sutherland (US) LLP

Down a rabbit hole: New Jersey regulations provide guidance on GILTI and FDII apportionment

The New Jersey Division of Taxation (Division) quietly issued special regulations addressing the inclusion and apportionment of global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII) for...more

McDermott Will & Emery

CARES Act Could Result in Taxation of More GILTI in New Jersey

The federal stimulus bill (the CARES Act), HR 748, which was signed into law by President Trump on March 27, includes certain corporate income tax provisions designed to provide relief to corporate taxpayers. One such...more

McDermott Will & Emery

BREAKING NEWS: Nebraska Bill Clarifies GILTI and Repatriation Are Deductible

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Most states have historically not subjected foreign-source income to state income tax. Consequently, since the passage of TCJA, the vast majority of states have opted not to tax GILTI (with most states explicitly decoupling...more

Morrison & Foerster LLP

MoFo New York Tax Insights Volume 11, Issue 1

Welcome to the latest issue of New York Tax Insights. In this issue we cover: • Our annual review of the developments we considered the Top 10 New York tax highlights in the past year (on page 1). •Three separate ALJ...more

McDermott Will & Emery

BREAKING NEWS: New Jersey Is Not GILTI! The Division Withdraws TB-85

McDermott Will & Emery on

Many New Jersey taxpayers have a reason to celebrate today as the Division of Taxation withdrew Technical Bulletin-85, providing for a special apportionment regime for global intangible low-taxed income (GILTI) and income...more

Morrison & Foerster LLP

New York State Governor Signs Legislation Exempting 95% of GILTI

The New York State Legislature has passed, and New York Governor Cuomo has now signed, legislation which provides for the exclusion of 95% of a corporation’s gross global intangible low-taxed income (“GILTI”) from its New...more

Akerman LLP - SALT Insights

Notable Changes To Florida Tax Law

The Florida legislature recently wrapped up its 2019 session. Of particular note, the following tax law changes were enacted. Documentary Stamp Tax – Deeds between Spouses Florida imposes a surtax – referred to as the...more

Faegre Drinker Biddle & Reath LLP

Minnesota Legislative: Update Recapping the 2019 Session

The 91st biennial session of the Minnesota Legislature convened on Tuesday, January 8, 2019, with a newly elected DFL Governor, former Congressman Tim Walz, and the only divided Legislature in the nation. The DFL also...more

McDermott Will & Emery

Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base

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On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 3 (March 2019)

NYC ALJ UPHOLDS TAX ON CAPITAL GAIN BASED ON NYC PRESENCE OF INVESTMENT THAT WAS SOLD - A New York City Administrative Law Judge has upheld the Department of Finance’s imposition of General Corporation Tax (“GCT”) on a...more

Bradley Arant Boult Cummings LLP

Three Things You Need to Know: How Trump’s “Tax Cuts and Jobs Act” Will Impact State Incentives and Project Recruitment - Economic...

As you may know, President Trump signed into law the Tax Cuts and Jobs Act (TCJA), enacting broad reforms to the Internal Revenue Code. How your state implements these reforms may have an impact on project recruitment and...more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

Bradley Arant Boult Cummings LLP

Summary of Newly Released ADOR Analysis of Federal Tax Reform's Impact on Alabama Income Tax Laws - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Update: Early Impact and Trends

Six months after the most significant U.S. tax reform legislation since 1986 was signed into law, it is still too early to predict the long-term effects. A number of technical uncertainties remain, and taxpayers are...more

McDermott Will & Emery

New Mexico Administrative Hearings Office Issues Timely Opinion Regarding State Taxation of Subpart F Income and Dividends from...

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Earlier this month, the New Mexico Administrative Hearings Office issued an opinion that addressed the questions on the minds of many state tax professionals in the wake of federal tax reform: under what circumstances can a...more

Skadden, Arps, Slate, Meagher & Flom LLP

New York State Responds to Federal Tax Reform

On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

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