On April 29, 2022, the New York State Department of Taxation and Finance issued two sets of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after January 1, 2015. Since the sweeping corporate tax reform was enacted, the Department has published a series of
Webcast: State tax considerations of IRC § 965
In this Bottom Line webcast, Eversheds Sutherland attorneys Aaron Payne and Todd Betor discuss the state tax consequences and considerations of IRC § 965. This videocast includes:
- A federal income tax overview of IRC § 965
- SALT considerations of IRC § 965
- Specific state responses
State Tax Reform Roundtables
The Tax Executives Institute’s (TEI) State and Local Tax Committee is holding a series of State Tax Reform Roundtables to enable SALT professionals to stay abreast of state tax developments associated with the Tax Cuts and Jobs Act, to engage with subject-matter experts, and to hear from peers regarding their “boots on the …
New York Bill Introduced to Exempt GILTI
On June 11, 2018, Senate Bill 8991 was introduced by New York Senate Majority Leader John Flanagan. The Bill would decouple from the federal treatment of Global Intangible Low-Taxed Income (GILTI).
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Non-Tax Lawyer’s Guide to the Tax Cuts and Jobs Act
On December 22, 2017, the largest overhaul of the nation’s tax code since 1986 was signed into law. While the reduction in the corporate income tax rate grabbed most of the headlines, in their article for the Summer 2018 edition of Partnering Perspectives, Eversheds Sutherland attorneys Jeffrey Friedman and Michael Resnick discuss several additional…
State Tax After TCJA: Treatment Of International Income
The Tax Cuts and Jobs Act, P.L. 115-97, made sweeping changes to the Internal Revenue Code, and will have far-reaching implications for state tax systems that broadly conform to the IRC.
In this article for Law360, Eversheds Sutherland attorneys Jeffrey Friedman, Eric Tresh, Todd Lard and Todd Betor focus on the major…
New York City: Penalty Relief Available for Certain Section 965 Underpayments
The New York City Department of Finance recently announced the availability of penalty abatements for certain taxpayers that have underpaid business taxes due to the inclusion of Section 965 income.
NYC Finance Memorandum No. 18-4 (PDF) describes tax considerations and late payment penalty relief for NYC taxpayers affected by Section 965 and subject…
Rhode Island: Section 965 Income Is not Deferrable for State Tax Purposes
The Rhode Island Department of Revenue recently released Advisory #2018-21 (PDF), which deals with “Section 965” income. The advisory states that the repatriation transition tax is not deferrable for Rhode Island state tax purposes.
Section 965 Background
On December 22, 2017, President Donald Trump signed into a law a bill popularly known as…