Alternative Apportionment – The Battle Moves International

Tax attorney Chris Wilson will be speaking on a panel at the Council on State Taxation's (COST) 55th Annual Meeting about the rising legislative efforts to impose additional taxes on Global Intangible Low-Taxed Income (GILTI), foreign dividends and Subpart F income. This trend has led to a range of apportionment challenges, particularly in securing rights to alternative apportionment methods for foreign income. The session will cover techniques to ensure statutory methods accurately reflect the income tax base and outline approaches to develop and support alternative apportionment strategies.