Tax Day is finally in the rearview mirror, and if you’re like many practitioners—with the phones quieter, the inbox manageable, and the September extension wave feeling comfortably far away—the temptation right now is to coast. Resist that temptation. Summer is the only stretch of the calendar when both you and your best clients have the bandwidth to think strategically; furthermore, this summer, there is a deadline-driven opportunity. In this article, I’ll walk through three moves every practitioner should be making between now and Labor Day. The first move has a hard statutory deadline of July 10, 2026. The second move is about turning your highest-value client conversations into billable advisory engagements. And third is about tending to the practice itself because a tax practice, like a garden, doesn’t survive without care.
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.
