This teleconference will prepare tax professionals to understand and deal with important multi-state trends and developments involving corporate income taxation on income from foreign affiliates and subsidiaries.
Taxation and tax implications of a U.S.-based multi-national company's foreign earnings don't just involve federal income tax and the IRS. Compliance with state corporate income taxes also poses critical, and often confusing, challenges.
To cite one example, companies with foreign subsidiaries or affiliates must wade through differing laws and regulations on treatment of Sect. 78 gross-up income from foreign dividends. Subpart F income always poses challenges, as do worldwide versus water's edge combined reporting and apportionment factors.
The degree to which a state will match the Internal Revenue Code on treatment of foreign income varies, making an overview of current multi-state trends in this area, fortified by some specific state examples, valuable for state tax specialists.
The panel will explore these and related topics:
- Do most states recognize various types of deductions for dividends received by the U.S. parent?
- How are states treating earnings and profits from foreign affiliates under Subpart F?
- Do states typically require worldwide combined, or water's edge, reporting of worldwide groups?
- Are states flexible with apportionment formulae when income comes from overseas?
Following the speaker presentations, attendees will have an opportunity to get answers to specific questions during the interactive Q&A.