Even if state lawmakers passed legislation decoupling from international taxation under the TCJA’s tax on global intangible low-taxed income (GILTI), their state might be in line to incorporate the OBBBA’s replacement tax on net CFC-tested income (NTCI), which is far more aggressive than GILTI when imposed at the state level.
Some States May Accidentally Tax…
Even if state lawmakers passed legislation decoupling from international taxation under the TCJA’s tax on global intangible low-taxed income (GILTI), their state might be in line to incorporate the OBBBA’s replacement tax on net CFC-tested income (NTCI), which is far more aggressive than GILTI when imposed at the state level.