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

GILTI Regs Support Foreign-Source Dividend Treatment by States

Scott Smith
Scott Smith

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 ...

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