GILTI, the Commerce Clause, & State Taxation of Foreign Source Income: Florida as a Microcosm
The Tax Cuts and Jobs Act (TCJA) substantially reformed U.S. international tax policy by introducing elements of a territorial tax system. State tax professionals must renew their focus on understanding foreign source income due to the TCJA. Based on past issues concerning foreign source income, this article presents a sample of potential future issues the state tax world will face. The article, originally published in the Journal of Multistate Taxation and Incentives, analyzes a state where a significant amount of international trade is conducted—Florida.