The rise of chatbots and AI assistants has blurred the lines between traditional search engines and conversational AI. Tools like ChatGPT and its latest iteration, GPT-4o, are reshaping how Certified Tax Planners (CTPs) search for tax information. A new and fragmented multi-search universe has emerged that offers CTPs a broader array of tools tailored to their specific needs for due diligence. Let's take a look at 10 new AI search tools that can maximize your efficiency today!
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.
