New Mexico Administrative Hearings Office Issues Timely Opinion Regarding State Taxation of Subpart F Income and Dividends from Foreign Affiliates


Alysse McLoughlin and Kathleen Quinn authored this bylined article on the circumstances under which a state may constitutionally impose tax on a domestic company’s income from foreign subsidiaries. “Since many state income taxes are based on federal taxable income, inclusion of these new categories of income at the federal level can potentially result in inclusion of this same income at the state level, triggering significant constitutional issues,” they wrote.

This column is reprinted with the publisher’s, Wolters Kluwer, permission from Global Tax Weekly, and originally appeared at pages 26,27; issue 294, June 28, 2018.