Thursday, January 4, 2018

Possible Impacts of Federal Tax Reform on State Taxation

Small Business Accounting - On December 22, 2017, President Trump signed into the "Tax Cuts and Jobs Act", P.L. 115-97 (the Act). While this is a significant event for federal taxation, it will also have far-reaching effects on state taxation.

Income taxes. Almost all state income taxes piggyback on the federal system by using a federal starting point for calculating state taxable income. As a result of this federal conformity, states incorporate a lot of federal provisions into their own state tax bases. States generally conform to varying versions of the Internal Revenue Code, with a few exceptions. Roughly half of the states imposing an income tax conform to the Internal Revenue Code as of a specific date (e.g., as of December 31, 2016) that the state legislature updates annually or periodically, while the other half conform to the current code on a rolling basis without need for legislative action. If federal income is changed due to tax reform, state taxable income may be as well, depending on the provision and the state.

States will not be directly impacted by the new federal tax rates because states use their own rates. States that impose a gross receipts tax in lieu of a net-income based tax may not be as significantly impacted by the Act.

Timing will be the overriding consideration for state conformity to federal tax reform. State legislatures will not be back in session until next year to even begin to respond to the sweeping federal changes. States that have static conformity dates will still conform to previous versions of the Code (absent legislative action), resulting in increased compliance burdens for taxpayers who have to compute a hypothetical federal starting point based on the old Code.

Changes to federal corporate deductions will impact states that conform to those provisions. Most states conform to Code Sec. 163, so the new federal limitations on interest deductions may result in a broader state tax base in those states. Similarly, changes to federal net operating loss (NOL) provisions may impact states that conform to the federal provisions. However, many states already decouple from the Code Sec. 172 federal NOL deduction and instead use a state-specific NOL. Elimination of the federal Code Sec. 199 deduction will also create a broadened tax base in states that conformed to the deduction.
Many state decisions to conform to or decouple from federal tax reform will be budget-driven. Unlike the federal government, nearly all states have to maintain balanced budgets. Therefore, they may not be able to afford to conform to federal provisions that would result in a revenue reduction for the state. For example, states may choose to decouple from or limit the new provisions allowing immediate expensing of capital investments. Many states have historically decoupled from special federal depreciation provisions, like bonus depreciation, because of revenue concerns. It will be interesting to see whether states consider the net impact of conformity to interest expense caps in conjunction with potentially disallowing the new expensing regime.

State conformity to the international provisions in the Act may be more complicated. Conformity to the foreign-source dividend exemption and repatriation of offshore earnings will depend on a state's treatment of foreign income. The impact may be ameliorated in combined reporting states where certain foreign dividends are already eliminated as intercompany transactions. Further, unlike the federal government, states are constitutionally limited in their ability to treat foreign dividends in a different manner than domestic dividends.

Both state and federal practitioners should carefully consider unintended state consequences of new federal planning opportunities that may arise from tax reform. For example, service providers may acquire new revenue streams or property to qualify for or increase the amount of the pass-through deduction. However, adding new business operations or property to a pass-through entity may trigger nexus for the entity or its owners in a new state or affect the apportionment factors used to calculate state tax liability.

The Act may also impact individual taxation at the state level. In states that use federal taxable income as the starting point for computing state taxable income, the state would conform to the federal increased standard deduction and the federal elimination of personal exemptions. States may or may not conform to other changes to federal personal income tax provisions. In later years, states will need to decide whether to conform to the expiration of these changes as well.

Limitations on the federal state and local tax (SALT) deduction may impact individuals indirectly at the state level. Inability to deduct more than $10,000 of state and local taxes for federal purposes will increase the cost of those taxes for individuals, especially in high-tax states. Notably, the Act does not allow taxpayers to pre-pay state income taxes to take advantage of higher deduction amounts in 2017 and avoid the 2018 cap. While there is no equivalent restriction relating to property or sales and use taxes, the structure of these taxes and local rules may limit the effectiveness of prepayment as a tax reduction strategy.

Estate taxes. While few states impose an estate tax, some states may see reduced revenues to the extent those states conform to the new federal exemption amount.

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Amare Berhie, Senior Accountant       
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