On April 17, 2019, the Maryland Comptroller of the Treasury issued Tax Alert 04-19, “Maryland guidance on the reporting and taxation of IRC Section 951A global intangible low taxed income,” further cementing the state’s tax climate as one that is bad for business.

Alert 04-19 describes the Comptroller’s treatment of GILTI. In their article published in Law360, Eversheds Sutherland attorneys Jeffrey Friedman and Todd Betor criticize Maryland’s guidance that requires the inclusion of GILTI as Maryland taxable income, the inapplicability of Maryland’s dividend subtraction, and Maryland’s unique apportionment factor representation.

Read the full article here.