Legal Alert: New York instructs taxpayers on GILTI apportionment
The New York State Department of Taxation and Finance released guidance in the form of tax return instructions addressing how it will account for global intangible low-taxed income (referred to as GILTI) for apportionment purposes. These instructions allow a taxpayer to include its net GILTI amount (rather than the total receipts related to the generation of GILTI) in the denominator of its apportionment factor, but do not require a taxpayer to include any amount related to GILTI in its numerator.
Originally published at stateandlocaltax.com
Citation
Eversheds Sutherland SALT, Legal Alert: New York instructs taxpayers on GILTI apportionment, SALT Shaker (January 16, 2019) [The Library at LexBlog, LEX-WK-37H45JAE, lexpid.org/37H45JAE]
Filed under
Practice Area
Statute
Locations
Organization