INC TX-GILTI APPORTIONMENT

Amends the Illinois Income Tax Act. Contains provisions concerning a deduction for income included in the taxpayer's federal adjusted gross income and deemed received under Section 951A (GILTI) or Section 952 (Subpart F) of the Internal Revenue Code. Fiscal Note (Dept. of Revenue) The bill refers to a corporate taxpayer's calculation of federal adjusted gross income. However, corporate taxpayers do not have a federal adjusted gross income. They have federal taxable income. Additionally, the bill proposes to disallow a subtraction at the State level that would have been made in tax years 2018 and 2019 for amounts included federally pursuant to Section 965 of the Internal Revenue Code. This is likely to raise issues as to the constitutionality of the proposal. For these reasons, an estimate cannot be determined.