PODCAST

State of Play: State Taxation of Foreign Income After the TCJA

Inside International Tax, Episode 05-2021 | As multinational companies grapple with proposed new international tax rules, what do they need to keep in mind when they intersect with various jurisdictions within the United States?

Gary Scanlon

Gary Scanlon

Principal, International Tax, Washington National Tax, KPMG US

Justin Hill

Justin Hill

Partner, Tax, WNT - SALT Income & Incentives, KPMG US

+1 214 840 8014

Dan De Jong

Dan De Jong

Senior Manager, Tax, KPMG US

+1 202-533-3548

Podcast overview

Multinational companies potentially face a labyrinth of state and local taxation in addition to the already-complex federal tax issues; these complexities have only increased in the wake of TCJA and proposed new international tax legislation at home and abroad. This podcast episode answers questions that arise from the interplay of federal and state tax systems: How does the foreign commerce clause affect state taxation of multinationals? How do states tax dividend income, GILTI, and Subpart F income? Do they permit a deduction for FDII? What’s the difference between states with fixed conformity, rolling conformity, and static approaches, and how does that affect their taxation of foreign income? 

Our host Gary Scanlon interviews KPMG State and Local Tax professionals Justin Hill and Dan De Jong about the state considerations that need to be front of mind for any company with operations in the United States and abroad. 


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