On April 29, California AB 71 was approved by the Assembly Housing and Community Development Committee. AB 71 was approved by the Assembly Committee on Revenue and Taxation earlier in April. The bill will now head to the Assembly Appropriations Committee for consideration. The Appropriations Committee is typically the final committee to consider a bill
GILTI Income
California AB 71, Proposing Repatriation Income and GILTI Inclusion, is Set for Second Committee Hearing
AB 71 was introduced earlier this year (see our prior coverage here) to provide additional state funding for homelessness programs, derived – in part – from increasing taxes on business income. In March, AB 71 was amended to eliminate steep corporate tax increases. The bill as amended, however, still would require corporate taxpayers that…
California AB 71 Proposes Corporate Income Tax Rate Increase and GILTI Inclusion Rules
On January 13, the authors of California Assembly Bill AB 71, a bill introduced to address the state’s homelessness problem, amended the bill’s provisions to propose an increase to the corporate income tax rate and to establish global intangible low-taxed income (GILTI) inclusion rules.
The bill provides that for taxable years starting January 1,…
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 purposes of the Corporation Business Tax (CBT).
Taking advantage of special authority granted by the New Jersey Legislature in conjunction with 2018 amendments to the CBT,1 the…
Webcast: SALT Implications of the CARES Act – April 14 at 12 pm ET
The recently enacted federal CARES Act makes significant changes to the I.R.C., including rolling back certain limitations on NOL utilization and increasing the interest expense limitation in I.R.C. § 163(j). Because of states’ differing rules on NOLs and conformity to the I.R.C., the CARES Act’s changes to the federal rules will have varying SALT implications.…
GILTI As Charged: Maryland’s Latest Inhospitable Tax Stance
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…
Podcast: New York apportionment of GILTI
In this podcast, our state tax team discusses New York guidance regarding the apportionment treatment of GILTI income.
Podcast: New Jersey apportionment of GILTI
In this podcast, our state tax team discusses New Jersey guidance regarding the apportionment treatment of GILTI income.