Rhode Island: Section 965 Income Is not Deferrable for State Tax Purposes
Posted on Apr 30, 2018 in State and Local Tax
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 the Tax Cuts and Jobs Act (TCJA). A new...
What are the State Tax Implications of International Tax Reform?
Posted on Apr 19, 2018 in State and Local Tax
What are the State Tax Implications of International Tax Reform? Jeff Friedman and others outline the key points at the COST 2018 Spring Audit Session/Income Tax Conference in snowy Boston, Massachusetts. These issues were also addressed in a recent article, “Waiting for the Other Shoe to Drop: State and Local Tax Implications of Federal Tax Reform – International Tax Provisions,” in...
Oregon Legislature Passes IRC Conformity Legislation, But Decouples from Certain Federal Tax Reform Provisions
Posted on Apr 17, 2018 in State and Local Tax
On April 10, 2018, and April 13, 2018, Oregon Governor Kate Brown signed into law S.B. 1529 and S.B. 1528 (the Bills), respectively, which provide a series of changes to Oregon’s income tax laws in response to recent federal tax changes as part of the federal Tax Cuts and Jobs Act. Most notably, the Bills: (i) update the state’s IRC conformity date to December 31, 2017; (ii) decouple...
Georgia Legislature Enacts Significant Income, Sales, and Property Tax Legislation
Posted on Apr 4, 2018 in State and Local Tax
The Georgia legislative session concluded on March 29, 2018. In addition to two major bills relating to federal tax reform, Georgia enacted several other pieces of notable tax legislation. View the full Legal Alert.
New York State Budget Adopts Substantial Changes in Response to Federal TCJA
Posted on Apr 2, 2018 in State and Local Tax
The New York Legislature passed its 2018-2019 Fiscal Year budget on March 30, 2018, which is expected to be signed into law by Governor Cuomo. The Legislature responded to the Tax Cuts and Jobs Act (TCJA) passed by the United States Congress late last year by excluding IRC § 965 repatriated income from New York taxable income. However, the final budget failed to address other TCJA...
Videocast: State Tax Implications of Federal Tax Reform
Posted on Mar 28, 2018 in State and Local Tax
The state and local tax (SALT) implications of federal tax reform are numerous, yet still often unclear. With states releasing new law and guidance about federal tax reform, taxpayers must stay abreast of this very dynamic area of law. In this videocast, Todd Lard and Todd Betor discuss the gating question to the SALT implications of federal tax reform—state conformity to the IRC—along...
Georgia passes legislation to provide deduction of GILTI from the state tax base
Posted on Mar 22, 2018 in International Tax, State and Local Tax
On March 21, 2018, the Georgia Legislature passed SB 328 (the Bill) to exclude IRC § 951A (GILTI ) from Georgia taxable income. The Bill treats GILTI as Subpart F income for purposes of the deduction under OCGA § 48-7-21(b)(8). View the full Legal Alert.
Idaho Enacts Corporate Income Tax Changes to Take Advantage of the Federal Tax Reform Legislation
Posted on Mar 16, 2018 in State and Local Tax
On March 12, 2018, Idaho’s governor signed into law H.B. 463 (the Bill), which provides a series of changes to Idaho’s income tax law in response to H.R. 1, popularly referred to as the Federal Tax Cuts and Jobs Act (the Act). The main changes to Idaho tax law include: (i) conformity, for tax years beginning after January 1, 2018, to the IRC as of January 1, 2018; and (ii) the...
Waiting for the Other Shoe to Drop: State and Local Tax Implications of Federal Tax Reform – International Tax Provisions
Posted on Mar 14, 2018 in International Tax, State and Local Tax
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...
How Will Georgia Conform to Federal Tax Reform? Annual Legislation Introduced
Posted on Feb 5, 2018 in State and Local Tax
The Georgia Legislature has introduced its annual Internal Revenue Code (IRC) conformity bill—HB 821. Georgia conformity is typically updated annually to apply for the most recent tax year. In light of the recently enacted federal tax reform, this year’s conformity bill will receive particular attention because of what tax reform provisions Georgia chooses to adopt and not to adopt....
Many State Tax Incentives Are Now Taxable Due to Federal Tax Reform
Posted on Jan 16, 2018 in State and Local Tax
Recently enacted federal tax reform is expected to generate $6.5 billion in additional federal revenue through 2027 by increasing corporate tax liability for certain state and local incentives. In their article for Bloomberg, Eversheds Sutherland attorneys Timothy Gustafson and Hanish Patel discuss the change and opportunities to minimize its impact. View the full...