Overview
Stephen Kranz, on behalf of the State Taxes After Reform (STAR) Partnership, praised Florida’s decision to exclude from the tax base foreign earnings deemed repatriated under IRC section 965 and recommended that the state confirm that GILTI will be treated similarly to subpart F income and deducted from the tax base. Kathleen Quinn noted that while many states have provided guidance on the treatment of repatriated income, not as many have issued guidance regarding GILTI.
