United States

Massachusetts: Estimated Tax Penalty Relief for Corporations Affected by the Transition Tax on Deferred Foreign Earnings

May 21, 2018
From KPMG TaxWatch

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The Massachusetts Department of Revenue has issued a Technical Information Release (TIR-18-4) providing that the Commonwealth will provide penalty relief for underpayments of corporate excise tax as a result of IRC section 965. The TIR first confirms that a corporation that has federal gross income attributable to section 965 must also report that income for Massachusetts corporate excise tax purposes. Next, the TIR states that the Department of Revenue intends to waive any estimated tax penalties imposed to the extent that the underpayment of estimated tax is attributable to section 965. To claim a waiver of penalties, a taxpayer must include Massachusetts Schedule M-2220, Underpayment of Massachusetts Estimated Tax by Corporations, with its return, accompanied by Massachusetts Schedule TDS, Taxpayer Disclosure Statement, identifying the amount of federal gross income attributable to Code § 965 as well as any explanation of the Schedule M-2220 calculation. Please stay tuned to TWIST for more updates on the state treatment of 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.