Kathryn Bibbo Addresses NH and VT Tax Developments at COST in St. Louis

Attorney Kathryn Bibbo participated in a panel on Northeast Developments at the annual conference for the Council on State Taxation (COST) in St. Louis on September 25th.  Included in the developments was a review of the 2024 legislative session in each state and potential legislative interests for the upcoming 2025 session.  Kathryn also addressed current tax developments affecting COST members, including New Hampshire’s taxation of foreign source income.  In particular, New Hampshire began including GILTI in the foreign tax base for the 2020 tax year.  Kathryn noted that the state’s current interpretation of the statute is to effectively tax 100% of GILTI, even though the legislation permitted the IRC 250 deduction to be incorporated into New Hampshire’s modification provisions.  This has caught many corporations by surprise and has the potential to create material disproportionality, as well as raising several constitutional issues involving factor representation.  For more information on these state tax developments, you may reach Attorney Bibbo at https://www.rathlaw.com/professionals/kathryne-h-bibbo/.