Massachusetts Will Treat GILTI as Dividends Received - McDermott Will & Emery

Massachusetts Will Treat GILTI as Dividends Received

Overview


Stephen Kranz said Massachusetts “should either allow factor representation of the deemed payor’s factors to avoid unconstitutional distortion or allow taxpayers to calculate their actual percentage of related expenses in addition to offering the 5 percent expense disallowance as a safe harbor” in regards to GILTI.