Bloomberg Tax
Aug. 1, 2023, 7:22 PM

GILTI Regs Support Foreign-Source Dividend Treatment by States

Scott Smith
Scott Smith
BDO LLP

Most states that impose corporate income taxes provide full or partial subtractions or deductions for a U.S. shareholder’s global intangible low-taxed income (GILTI) that is included in the taxpayer’s federal taxable income “starting point” under Section 951A of the Internal Revenue Code. These states typically provide a subtraction or deduction of either the net amount of §951A GILTI after the §250 GILTI deduction or the entire §951A GILTI amount without (or add-back of) the federal GILTI deduction.

However, several U.S. jurisdictions—including Maryland, Nebraska, New York City, Washington, D.C., and West Virginia—do not. Instead, these jurisdictions conform to the federal treatment ...

Learn more about Bloomberg Tax or Log In to keep reading:

Learn About Bloomberg Tax

From research to software to news, find what you need to stay ahead.

Already a subscriber?

Log in to keep reading or access research tools.