Do you love giving your clients great news? I do. Especially when it is about a tax benefit they can receive as the result of the hard work that they have put in throughout the tax year. That is what the overtime deduction is for the taxpayer. A little bit of tax relief for their hard work. But before sharing the good news with them, we need to make sure that we understand that No tax on overtime is not a blanket statement that will apply to all overtime compensation and all taxpayers. It is our responsibility to do our due diligence to understand who it will impact and how.
State Tax Planning with the “80/20 Company” Exclusion
Ted Stotzer
Many multinational groups find that foreign-source dividends and other income earned by domestic affiliates are fully or partially subject to state income taxation, even where the federal system provides an exemption. This state-level “leakage” can be material – particularly in high-tax jurisdictions – and is often overlooked because the income appears sheltered at the federal level. For groups with predominantly foreign operations, a starting structure or a restructuring that causes one or more domestic affiliates to qualify as an “80/20 company” can substantially reduce or eliminate state taxation on that income.
