The state and local tax (SALT) impact of the recently enacted federal tax reform is still being assessed. Because of states’ broad conformity to the federal income tax laws, many of these changes will have an impact on taxpayers’ SALT liabilities.
In their article for Bloomberg Tax, Eversheds Sutherland attorneys Jeff Friedman, Todd Betor and Michael Spencer focus on the SALT consequences stemming from the following international provisions of the Tax Cuts and Jobs Act:
• a one-time “transition tax” on untaxed accumulated earnings and profits of controlled foreign corporations and certain other foreign corporations.
• 100% dividends received deduction for certain foreign source dividends.
• current taxation of certain US taxpayer’s global intangible low-taxed income.
• deduction allowed to certain US taxpayers for foreign derived intangible income.
• a base erosion and anti-abuse tax imposed on certain US taxpayers.