There has never been a moment in the accounting profession, quite like this one. For decades, new tools have promised efficiency and accuracy, but artificial intelligence is different. AI is not just another tool, it’s a change in how we work. AI can automate tasks that were formerly part of our everyday work, such as data entry, reconciliations, reporting, and even initial research.
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.
