Reed Smith Client Alerts

Have you considered the state impact of the deemed repatriation? Is it beneficial to calculate your interest expense limitation on a combined basis? Can you take Pennsylvania bonus depreciation? Do you want to decouple from the state tax impact of federal tax reform entirely?

Authors: Kyle O. Sollie Sebastian C. Watt

American flag outside of US Dept of Commerce

In this four-part video series, Kyle Sollie and Sebastian Watt discuss handling the state impact of federal tax reform. Jump right to what’s important to you:

  • Transition tax and repatriation, part 1:
  • Determining your inclusion
  • Watch out! Tax on the actual repatriation (CA Example)
  • Mitigating the tax: factor representation


  • Transition tax and repatriation, part 2:
  • Excluding as not unitary — but which year do I test for unity?
  • Challenging the tax: Kraft
  • Don’t lose your NJ NOLs!
  • The double-deduction (a look at NY and PA)
  • GILTI, state DRDs, GILTI + add-back = double tax surprise