About the Course
Introduction
This webinar will examine how recent federal international tax changes under the One Big Beautiful Bill Act (OBBBA), particularly the transition from GILTI to net CFC tested income (NCTI), are reshaping the state taxation of foreign income for multistate taxpayers. Our panel of state and local tax experts will analyze how the elimination of the QBAI exclusion, permanent changes to the Section 250 deduction, revised expense allocation rules, and modified foreign tax credit mechanics are creating significant—and often unexpected—state tax exposure.
Description
As states incorporate NCTI through rolling or updated conformity—often without foreign tax credits—the combined effect of expanded NCTI bases, larger Section 78 gross ups, and outdated apportionment rules can significantly increase state taxable income. States continue to apply widely divergent methods for taxing foreign income. Some states include NCTI directly in the tax base; others treat it as dividend or Subpart F income subject to partial exclusion; and still others apply addback, subtraction, or apportionment rules that can significantly distort the tax base. For many taxpayers, routine conformity now creates unintended state tax exposure that departs sharply from both prior practice and federal intent.
Listen as our panel of SALT practitioners explains how OBBBA has altered the state taxation of foreign income, identifies jurisdictions posing heightened risk under the new NCTI framework, and provides practical guidance for navigating compliance, planning, and audit considerations in today's evolving state tax environment.
Presented By
Ms. Girmscheid is a Partner in RubinBrown’s Tax Services Group, specializing in State and Local Tax (SALT) services. With more than 18 years of public accounting experience, she advises clients on complex multistate tax matters, helping organizations navigate compliance requirements, manage risk, and identify tax-saving opportunities. Ms. Girmscheid provides strategic tax consulting, compliance, tax provision, and planning services to corporate, pass-through, and individual clients with multistate and international operations. Her expertise encompasses all aspects of state income and franchise taxation, including merger and acquisition transactions, tax due diligence, state tax controversy and audit representation, ASC 740 income tax accounting, and multistate tax compliance. Throughout her career, Ms. Girmscheid has served both Fortune 500 and middle-market companies across a diverse range of industries, including manufacturing, retail, consumer products and services, financial services, real estate, technology, and transportation. She is particularly experienced in assisting organizations with significant multistate footprints and complex tax structures, delivering practical solutions that align tax strategies with broader business objectives.
Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals manage state and local tax risks and exposure, including assessing the strength of corporate tax positions, evaluating whether charges are subject to sales tax, and representing taxpayers in disputes with revenue agencies throughout the U.S. He brings a practical, pragmatic approach to state and local taxation, one that takes into account reserve considerations, legal and administrative guidance, and anticipated revenue agency responses. He is particularly experienced with New York and Massachusetts tax controversies, corporate tax planning, assessing the anticipated state tax consequences of mergers and acquisitions, and analyzing the taxability of electronic commerce and emerging business models. He has resolved disputes with most tax agencies in the United States, and also has broad experience with IRS audits and appeals, and unclaimed property.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
Date + Time
- event
Tuesday, July 7, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Overview of state conformity methods
II. GILTI vs. NCTI
III. Section 250 deductions
IV. IRC Section 163(j)
V. Subpart F
VI. Worldwide and water's edge reporting
VII. Other foreign income
VIII. Relative case law
IX. State and federal challenges
The panel will cover these and other critical issues:
- State transitions from GILTI to NCTI
- How the elimination of the QBAI exclusion impacts state taxable income
- Differences between rolling, static, and selective conformity
- How specific states apply the 163(j) interest limitations
Learning Objectives
After completing this course, you will be able to:
- Distinguish key state taxable income differences under GILTI and NCTI
- Ascertain how the change from GILTI to NCTI impacts state taxation of foreign income
- Determine how conformity methods impact state taxation of foreign income
- Identify how specific states interpret the Section 163(j) interest limitation
- 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 international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI/NCTI, Subpart F, and the related Section 250 deductions.
BARBRI, 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.
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