The year is 2027, and the landscape of tax accounting has undergone a dramatic transformation. Artificial Intelligence (AI) has automated many traditional tasks once considered the bedrock of the profession. Yet, contrary to fears of widespread job losses among tax preparers, this technological revolution has ushered in a new era – Post-Cognitive Tax Accounting. This paradigm shift is redefining the role of tax professionals, opening opportunities to explore uncharted territories that leverage human intuition, creativity, and strategic insight.
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.
