Minnesota began taxing 50% of GILTI in 2023, and Illinois followed suit in 2025. These states are particularly problematic because they have large populations (driving apportionment) and high tax rates. And absent alternative apportionment, they don’t provide meaningful factor representation or allow worldwide elections. Moreover, there are upcoming deadlines to consider. In particular, calendar-year taxpayers seeking to mitigate GILTI through an alternative apportionment petition in Illinois must file their request by June 17
Join Dave Dorner—former General Counsel of Illinois Department of Revenue—and Sebastian Watt—a lawyer with a long-standing focus on federal-state base issues—for a webinar discussing how to mitigate GILTI on your 2025 returns, with a particular focus on Illinois, Minnesota, and New York City.
We’ll discuss:
- Strengthening your factor representation arguments for 2026
- Importance of knowing your tax liability as if you filed worldwide
- Posturing for settlement negotiations
- Procedural options to perfect your position
