Topic
Repatriation tax
6 published works
Dollars & Sense
Gray Reed Tax Partner Discusses Mandatory Repatriation Tax Ruling on Podcast
By Admin
On June 20, 2024, the Supreme Court issued a narrow ruling upholding the constitutionality of the transition tax in Moore v. United States. The Court did not address issues related…
Inside SALT
2018 Recap: State Responses to the Repatriation Transition Tax in the Tax Cuts and Jobs Act
By Stephen P. Kranz, Alysse McLoughlin, Diann Smith
Since the Tax Cuts and Jobs Act (TCJA) passed in December 2017, over 100 bills were proposed by state legislatures responding to the federal legislation. Thus far in 2018, nearly…
Tax Talks
New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs
By Martin T. Hamilton, Martine Seiden Agatston, Timothy Donovan
On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”), which provides that a repatriation deemed to have been received by a registered investment…
SALT Shaker
Rhode Island: Section 965 Income Is not Deferrable for State Tax Purposes
The Rhode Island Department of Revenue recently released Advisory #2018-21 (PDF), which deals with “Section 965” income. The advisory states that the repatriation transition tax is not deferrable for Rhode…
Inside SALT
Governor Cuomo’s Amended Budget Bill Would Address the Deemed Repatriation Dividend Provisions
By Alysse McLoughlin, Diann Smith, Kathleen M. Quinn, Stephen P. Kranz
New York is the latest state to address certain state tax implications of the 2017 federal tax reform bill, the Tax Cuts and Jobs Act. Governor Andrew Cuomo’s 30-day amendments…
Inside SALT
Connecticut Responds to the Federal Repatriation Tax
By Stephen P. Kranz, Kathleen M. Quinn, Diann Smith, Alysse McLoughlin
Earlier this month, Connecticut Governor Dan Malloy released his Governor’s Bill addressing the various state tax implications of the federal tax reform bill enacted by Congress in December 2017, commonly…