At a Glance...
Have you considered the state impact of the deemed repatriation? Is it beneficial to calculate your interest expense limitation on a combined basis? Can you take Pennsylvania bonus depreciation? Do you want to decouple from the state tax impact of federal tax reform entirely?
In this four-part video series, Kyle Sollie and Sebastian Watt discuss handling the state impact of federal tax reform. Jump right to what's important to you:
1. Transition tax and repatriation, part 1:
- Determining your inclusion
- b. Watch out! Tax on the actual repatriation (CA Example)
- c. Mitigating the tax: factor representation
2. Transition tax and repatriation, part 2:
- Excluding as not unitary — but which year do I test for unity?
- Challenging the tax: Kraft
- Don't lose your NJ NOLs!
- The double-deduction (a look at NY and PA)
- GILTI, state DRDs, GILTI + add-back = double tax surprise
3. Investment in business assets: bonus depreciation and interest expense
- a. Don't lose your PA or Philly depreciation
- "Accidental" conformity to 100% bonus: IL and RI
- Calculate your interest expense limitation on a consolidated basis — even in separate states
4. Decouple entirely: how rolling IRC conformity may not be rolling conformity
This article is presented for informational purposes only and is not intended to constitute legal advice.