Enacted into law on July 4, 2025, the One Big Beautiful Bill Act is the biggest set of tax law changes since the 2017 Tax Cuts and Jobs Act (TCJA). The provisions discussed in this article impact business taxpayers for tax year 2025 and must be considered immediately for proactive tax planning purposes, future tax withholding, and estimated tax payment calculations. Clients have questions, and we can generally give them the answers they seek; however, some will require future IRS guidance for complete clarity.
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.
