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N.J.'s Revised Foreign Income Tax Rules Still Baffle Businesses

Aug. 26, 2019, 8:31 AM

New Jersey’s latest tax guidance to multinational companies is leaving them questioning how to factor international provisions from the 2017 federal tax overhaul into their state tax calculations.

The state Division of Taxation released revised guidance Aug. 22 on tax treatment of global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII)—both created by the 2017 tax law. The latest piece of guidance replaces the state’s aggressive treatment of GILTI and comes after relentless pushback from multinationals.

Companies had pressured the state through tax practitioners and business groups like the Council on State Taxation, the New Jersey...

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