The One Big Beautiful Bill Act makes good on several promises President Trump made on the campaign trail. Of course, tax legislation, unlike campaign sloganeering, rarely lends itself to sound bites. It is the opposite of pithy and the opposite of memorable. Even the bill’s title pushes the boundaries of memorability. If you’re looking for the tax promises section of the OBBBA it is in Title VII–Finance, Subtitle A–Tax, Chapter 2–Delivering on Presidential Priorities To Provide New Middle-Class Tax Relief. We take a closer look in this article.
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.
