The Tax Cuts and Jobs Act, P.L. 115-97,[1] 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 state income tax implications of the TCJA’s international tax provisions, including:
- The transition tax imposed by revised IRC § 965;
- The foreign-source dividends received deduction, or DRD, allowed by new IRC § 245A;
- The tax on global intangible low-taxed income, or GILTI, in new IRC § 951A and related deduction in IRC § 250;
- The deduction allowed for foreign-derived intangible income, or FDII, in new IRC § 250; and
- The base erosion anti-abuse tax, or BEAT, imposed under new IRC § 59A.