President Trump’s campaign promises oriented toward working stiffs and geezers – No Tax on Tips, No Tax on Overtime, No Tax on Car Loan Interest, No Tax on Social Security – were not precisely fulfilled in the Big Beautiful Bill, but they were not ignored. Rather than the exclusion implied by “No Tax,” we get deductions. Just so we don’t miss the connection, the first three get their own chapter in the Big Beautiful Bill – Delivering on Presidential Priorities to Provide New Middle-Class Tax Relief. The bone thrown to seniors is an exemption.
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.
