Tennessee has enacted changes or modifications for global intangible low-taxed income (GILTI) and repatriation income.
Excise Tax Subtractions for GILTI and Repatriation Income
The new rules create excise tax subtractions from net earnings and losses for amounts included in federal taxable income for both:
Addback Rule for GILTI and Repatriation Income
However, an addback is required before taking:
the deduction allowed in IRC Sec. 250 for taxpayers with GILTI; and
participation exemptionin IRC Sec. 965(c).
Tennessee taxpayers must make an addition to net earnings or losses equal to 5% of the amount of GILTI and Section 965 income before taking those deductions.
The modifications apply to all tax periods beginning on or after January 1, 2018.
Ch. 306 (S.B. 558), Laws 2019, effective May 8, 2019, applicable as noted