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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Corporate Tax

Date & Time
  • event Date

    Thursday, July 13, 2023

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$247.00
CPE
ALL

This course will discuss the multitude of differences in state requirements for reporting foreign income. Our panel of experts in foreign income tax matters will explain the latest developments in state taxation of GILTI income and the corresponding Section 250 deduction and payments for practitioners and advisers reporting foreign income in multiple states.

Faculty

Ilya A. Lipin
Tax Principal, Mid-Atlantic Region State and Local Tax Practice Leader
BDO USA

Mr. Lipin provides clients with state tax advice in the area of multistate income taxes, sales and use taxes, tax controversy, compliance, and various SALT aspects that arise from M&A transactions.

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Katie Girmscheid
Managing Director, State and Local Tax
BDO USA

Ms. Girmscheid is a Senior Manager in BDO Chicago’s State and Local Tax Practice with over 9 years in public accounting. Katie specializes in on multi-state organizations, including complex multi-tiered partnerships, ensuring our clients meet all compliance requirements and deadlines. Most of her clientele are corporate entities with heavy state and international presence.

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Raymund Dagarag
Tax Partner STS-SALT
BDO USA

Mr. Dagarag has over 25 years of experience addressing multijurisdiction state & local tax issues for businesses ranging from start up to global public companies.

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Description

There are multiple methods employed by states to tax, or not tax, foreign income. GILTI income may be included unadjusted as part of federal taxable income in some states. States may allow a subtraction from federal taxable income and a corresponding addition of the GILTI Section 250 deduction. Other states have developed unique criteria for GILTI taxation with Tennessee, for example, requiring a five percent addback of GILTI income and Maine allowing a 50 percent deduction for the amounts included in state income.

In addition to Section 951A income, there are significant differences in 163(j) interest adjustments and even foreign exchange gains and losses. SALT practitioners must be aware of the latest state developments surrounding taxation of foreign income to report tax accurately and avoid penalties in states that tax foreign income.

Listen as our panel of SALT experts in foreign tax matters explains the latest development in state taxation of foreign income.

Outline

  1. Overview of state methods
  2. GILTI
  3. Section 250 deductions
  4. 163(j)
  5. Foreign exchange rate gains and losses
  6. State filing deadlines
  7. Other foreign income

Benefits

The panel will cover these and other critical issues:

  • The latest state developments in taxing foreign income
  • Recent state legislation relative to the taxation of foreign income
  • Common state methods for taxing Section 951A income
  • How states treat 163(j) interest

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Distinguish the federal and state tax treatments of foreign income
  • Ascertain the latest developments in state taxation of foreign income and the impact of recent federal changes to the taxation of foreign income
  • Recognize common state methods for taxing IRC 951A income
  • Establish how states treat IRC 163(j) interest
  • Identify the significant differences in state taxation of repatriation payments under IRC 951A and IRC 163(j) interest adjustments

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).