Nebraska’s tax department has issued guidance confirming its position that IRC 965 deemed repatriation income: 1) must be included in a taxpayer’s corporate income tax base (less the IRC 965(c) deduction); and 2) does not qualify for the state’s dividends received deduction. Nebraska Dep’t of Revenue, Gen. Info. Letter 24-19-1 (Sept. 13, 2019).
Carley Roberts presents on “The Taxation of Section 965 Deemed Repatriation” at COST’s Spring Audit Session & Income Tax Conference 2019 on May 1.
Three years ago, the U.S. Supreme Court invalidated a portion of Maryland’s personal income tax scheme on grounds that it violated the dormant commerce clause of the U.S. Constitution. In Comptroller of the Treasury of Maryland v Wynne, the Court held that Maryland’s credit mechanism for income taxes paid to other states impermissibly discriminated against interstate commerce because it allowed a credit against state taxes paid but not county taxes, resulting in double taxation on some income earned outside the state.
On February 8, Marc Simonetti and Jeffrey Vesely present “Income Tax – TCJA and Other SALT Matters” during Tax Executives Institute’s New England Chapter Meeting.
On January 29, Carley Roberts presents “Federal-State Tax Conformity after the TCJA” during Tax Policy Center’s How Are States Responding to the Tax Cuts and Jobs Act? Conference.
(This article originally appeared in the Journal of Multistate Taxation and Incentives, Vol. 28, No. 9.)
The question of whether or not an individual is a resident of a particular state has always been an important issue in the area of state personal income taxation. California, because of its top marginal personal income tax rate of 13.3 percent1, and the large number of high-wealth individuals living in the state, always has been one of the most significant jurisdictions for this issue. Indeed, California, at 13.3 percent, currently has the highest personal income tax rate of any state.2 The significance of the high California rate, and the residency issue in general, recently has taken on added significance as a result of two federal tax law changes.
On November 16, Carley Roberts and Marc Simonetti present “Federal Tax Changes Rocking the SALT Landscape” during Tax Executives Institute’s New Jersey All-Day Seminar.
(This article was originally published by Law360.)
California’s A.B. 2731 seeks to accomplish what the federal Tax Cuts and Jobs Act did not, namely, to close the carried interest “loophole.” Currently making its way through state assembly committees, AB 2731 would impose an additional 17 percent tax on interest income derived from investment management services on taxpayers subject to California’s personal income tax law.
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