As the federal student loan system enters a new era, advisors are tasked with helping clients navigate the practical implications of recent reforms. The One Big Beautiful Bill Act (OBBBA) has redefined borrowing limits and repayment options, creating fresh challenges for borrowers at every stage of higher education. Whether clients are weighing school choices or managing existing student debt, understanding these updates is key to providing informed financial guidance. In Part 2 of our OBBBA student loan series, we explore how these changes could play out for common borrower situations and what advisors should be aware of to confidently guide clients through the post-OBBBA student loan landscape.
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.
