Statute
GILTI
16 published works
SALT Shaker
New York State proposes changes to GILTI
By Todd Betor
On January 8, 2025, a group of New York State Senators introduced S953, which proposes to increase the gross amount of GILTI under IRC § 951A included in the New York State…
SALT Shaker
California doesn’t need GILTI
By Jeremy Gove, Annie Rothschild
In this episode of the SALT Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove is joined by Associate Annie Rothschild for a quick review of GILTI, a 2021 failed…
SALT Shaker
GILTI and California
By Eric Coffill, Annie Rothschild
Currently, there is no California conformity to GILTI, and GILTI is not part of the tax law in California unless and until the California Legislature adopts it. In this column…
SALT Shaker
California AB 71, Proposing Repatriation Income and GILTI Inclusion, Set for Hearing in Assembly Appropriations Committee
By Timothy Gustafson, Annie Rothschild
California AB 71 is set for hearing in the Assembly Appropriations Committee tomorrow, May 12, at 9 am. The Appropriations Committee is typically the final committee to consider a bill…
Whatever Source Derived
GILTI and California: Show Me the Money Edition
Back of the envelope calculations indicate significant revenue can be raised if California conforms to GILTI.The California Legislature is considering a bill (AB 71) that would subject 50% of a category…
Inside SALT
CARES Act Could Result in Taxation of More GILTI in New Jersey
By Alysse McLoughlin, Kathleen M. Quinn
The federal stimulus bill (the CARES Act), HR 748, which was signed into law by President Trump on March 27, includes certain corporate income tax provisions designed to provide relief…
Rubin On Tax
Good News/Bad News on GILTI Exclusion for Highly Taxed Income
I noted in my February 23, 2018 posting that the taxation of GILTI under Code §951A does not apply to foreign base company income and insurance income that is excluded…
Inside SALT
New York Clarifies GILTI Exemption; New Jersey Now Lone Major Commercial State to Significantly Tax Foreign Income
Stephen Kranz is quoted in a press release from STAR Partnership regarding state-level action on the Tax Cuts and Jobs Act’s GILTI provisions. Read the full real press release.
Inside SALT
Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base
By Stephen P. Kranz, Kathleen M. Quinn
On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC…
SALT Shaker
GILTI As Charged: Maryland’s Latest Inhospitable Tax Stance
On April 17, 2019, the Maryland Comptroller of the Treasury issued Tax Alert 04-19, “Maryland guidance on the reporting and taxation of IRC Section 951A global intangible low taxed income,”…