United States

Rhode Island: Guidance Upcoming on Corporate Treatment of Section 965 Income

Apr 23, 2018
From KPMG TaxWatch

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The Rhode Island Division of Taxation recently issued an advisory (ADV 2018-19) that addresses how to report deferred foreign income for Rhode Island tax purposes. The advisory document explains the treatment for individuals and pass-through entities, but states that guidance for corporate taxpayers is “coming.” For individual purposes, because section 965 income is included in federal adjusted gross income, it will be included on Line one of the Rhode Island 1040 return. Likewise, for partnership purposes, the income will be included on the Rhode Island Form 1065. The guidance does note that, for apportionment purposes, section 965 income should be included in the denominator only and not in the numerator. While the guidance clarifies that individuals and pass-through entities cannot defer the actual tax due on repatriated income, for corporate tax purposes the advisory states that this question is “not applicable.” Please stay tuned to TWIST for more updates on reporting section 965 income. 


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The following information is not intended to be "written advice concerning one or more federal tax matters" subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.