Video & Transcript : 'subpart F income' :
Page 1 of 500
AZ
Transcript Highlights:
- Because obviously some business owners have tremendous income swings in liability and non-liability,
- And when you're classified that way, the valuation is effectively linked to its income potential as agricultural
- Agricultural property is valued statutorily with an income-based approach, supported by leases and sworn
- We didn't have income tax. We didn't have sales tax. We had property tax.
- but system so it is while it should be simple I want to lift up that it may not be now that we have income
Keywords:
tax penalties, filing, tax returns, administration, Arizona Revised Statutes, HB2288, foreign dividends, corporate income tax, Arizona tax, A.R.S. 43-1122, subtraction, gross income subtraction, multinational corporations, GILTI, global intangible low-taxed income, subpart F income, IRC 78 gross-up, foreign-source income, international tax conformity, corporate tax base
AL
Alabama 2025 Regular Session
Alabama Senate Finance and Taxation General Fund Committee Apr 16th, 2025
Finance and Taxation General Fund
Transcript Highlights:
- However, when you purchase a home, they still calculate your property taxes and your debt to income ratio
- proof you're 100% disabled and qualify for those exemptions, you do not include it in your debt to income
- This is trying to make a true... ...indication of what the vets' income and outgo is.
- annual state of tobacco control report, Alabama received an FS. control report, Alabama received an F.
- If this legislation continues to move forward, we will continue to receive an F for our tobacco tax rate
Committee:
Senate Finance and Taxation General Fund
Keywords:
virtual currency, cryptocurrency, tax exemption, state tax law, digital assets, ad valorem tax, tangible personal property, business incentives, economic impact, firefighter, license plate, fees, funds distribution, support programs, memorial, disabled veterans, property tax exemption, debt-to-income ratio, homestead, veterans affairs
AL
Alabama 2026 Regular Session
Alabama Senate Education Policy Committee Feb 25th, 2026
Education Policy
Transcript Highlights:
- Remember Senator Smith, what's going to happen at the schools and and and I've this just a pick up from F&
- /c> and and and I've this just a pick up and and and I've this just a pick up from<00:05:08.560><c> F&
- </c><00:05:12.880><c> So</c> from F&T Ed. We in policy now. Okay. So from F&T Ed.
- My concern is simply the fact is not that we're not wouldn't pass a statute, but we f to make this a
- we're not wouldn't pass a statue,<00:18:52.320><c> but</c><00:18:52.559><c> we</c><00:18:52.720><c> f<
Committee:
Senate Education Policy
Keywords:
military installations, tall structures, local government, construction approval, wind energy facilities, archives, history, board of trustees, vacancies, government control, computer science, education reform, digital literacy, high school graduation, teacher training, education, public schools, constitution amendment, national anthem, weekly broadcast
US
US Federal 2025-2026 Regular Session
US House Floor Proceedings (Wednesday, December 10, 2025)
US Federal House Floor Meeting
Keywords:
impeachment, presidential power, violence, judiciary, political climate, democracy, executive abuse, lawmakers, committee election, House of Representatives, governance, legislative process, representation, investment, private funds, economic growth, capital formation, small businesses, financial regulation, senior investors
US
US Federal 2025-2026 Regular Session
US House Floor Proceedings (Monday, April 7, 2025)
US Federal House Floor Meeting
Transcript Highlights:
- Speaker, we are gathered here today to honor the lives of Staff Sergeants Jose Dues Jr., Evan F.
- Earned income tax credit, what I think is the most damaging, the low-income housing programs, the health
- low-income is the most damaging, the low-income housing<07:42:50.200><c> programs,</c><07:42:51.200>
- Children with disabilities in rural and low-income communities.
- Children with disabilities in rural and low-income communities.
Keywords:
HIV/AIDS, National Black HIV/AIDS Awareness Day, Black health, public health, HIV testing, HIV prevention, PrEP, antiretroviral therapy, viral suppression, U=U, undetectable equals untransmittable, AIDS, Minority AIDS Initiative, community health centers, culturally competent care, health disparities, racial disparities, health equity, Black Americans, African Americans
TX
Transcript Highlights:
- have, that we're talking about here instead... that go to our schools and our health care for low-income
- I also wanted to mention that as far as our calculation goes, 26 states have cut income tax rates since
- So, like, the sort of return across... across all five income quintiles is sort of more even.
- To produce income.
- We support the exemption of the first $250,000 in income-producing property, and we strongly support
Committee:
House Ways & Means
Keywords:
HB 8, school finance, compressed tax rate, maximum compressed tax rate, MCR, PYMCR, property tax, school district taxes, Education Code, Tax Code, state aid, school funding formula, local school taxes, Texas school finance, tax rate compression, public education funding, ad valorem tax, tangible personal property, income-producing property, business personal property
MN
Transcript Highlights:
- Uh, HR1 also makes changes to subpart F income.
- And the last subpart F provision changes the rules on when subpart F income and GILTI is recognized as
- </c><00:31:56.320><c> F</c><00:31:56.480><c> income</c> through rules for subpart F income through rules
- And the last subpart F F income.
- /c><00:32:24.000><c> is</c> subpart F income and guilty is subpart F income and guilty is recognized<
Committee:
Senate Taxes
MN
Transcript Highlights:
- F income.
- So these guilty and subpart F income.
- This relates to subpart F income, and it excludes non-U.S. business income from subpart F income under
- from subpart F non US business income from subpart F income<00:31:48.080><c> under</c><00:31:48.399>
- </c><00:32:13.360><c> F</c> by reducing the amount of subpart F by reducing the amount of subpart F income
Committee:
House Taxes
Keywords:
January 6 insurrection, pardon, law enforcement, violent crimes, public safety, justice system, political accountability, Blaine, local sales tax, special tax, restaurant tax, lodging tax, admissions tax, amusement tax, hotel tax, redevelopment, capital improvements, municipal finance, bonding authority, tourism tax
CA
California 2025-2026 Regular Session
Joint Hearing Senate Revenue and Taxation Committee and Assembly Revenue and Taxation Committee Feb 11th, 2026
Transcript Highlights:
- foreign corporations that have what is called subpart F income, as well as foreign corporations to the
- It actually does contain nominally foreign-source income in the context of subpart F income.
- F income can be transformed into NCTI income, NCTI income can be transformed to subpart F income, and
- we only include subpart F income.
- There's the subpart F question, for instance.
Summary:
The joint informational hearing examined California’s taxation of multinational corporations, especially the state’s water’s-edge election versus worldwide combined reporting. The LAO and Franchise Tax Board explained the basic mechanics of unitary taxation, apportionment, and how water’s-edge generally excludes most foreign subsidiaries while worldwide reporting includes the full unitary group. FTB officials said water’s-edge filers are a small share of corporate filers but account for a large share of tax liability, and they described filing trends, industry mix, and the administrative steps needed to administer either system.
Members and witnesses debated the policy trade-offs. Supporters of moving away from water’s-edge argued that it enables profit shifting, especially for large multinational and IP-heavy firms, and that eliminating it could raise significant revenue and improve fairness for smaller domestic businesses. They cited estimates of billions in potential revenue and said California already has the audit and reporting infrastructure to handle worldwide reporting, though some transition time would be needed. Opponents argued that worldwide reporting would tax foreign activity unrelated to California, create double taxation, increase compliance burdens and litigation, and could be difficult for foreign-based multinationals to document. They also warned that some of the revenue estimates are highly uncertain because foreign affiliate income is not directly observable.
Committee members asked about foreign government pushback, the risk of companies leaving California, the effect on intellectual property shifting, and whether federal or Supreme Court action could block a change. Witnesses generally said major firms would be unlikely to leave because California taxes sales rather than physical presence, but some costs could be passed on to consumers. The panel also discussed alternatives such as conforming to federal international tax rules like NCTI/GILTI and adding anti-abuse rules. No vote or bill action was taken; the hearing was informational only.
CA
California 2025-2026 Regular Session
Joint Hearing Senate Revenue and Taxation Committee and Assembly Revenue and Taxation Committee Feb 11th, 2026
Transcript Highlights:
- foreign corporations that have what is called Subpart F income, as well as foreign corporations to the
- It actually does contain nominally foreign-source income in the context of subpart F income.
- F income can be transformed into NCTI income, NCTI income can be transformed to subpart F income, and
- we only include subpart F income.
- There's the subpart F question, for instance.
Summary:
The joint informational hearing examined California’s taxation of multinational corporations, especially the Water’s Edge election versus worldwide combined reporting. Chairs opened by framing the issue as a review of whether current rules fairly and sufficiently tax foreign subsidiary income, given profit shifting concerns, budget pressures, and the long history since Water’s Edge was adopted in the 1980s. The first panel from the Legislative Analyst’s Office and Franchise Tax Board explained the mechanics of unitary taxation, apportionment, and the Water’s Edge election, and provided filing data showing Water’s Edge filers are a small share of returns but account for a large share of corporate tax liability. FTB witnesses said the agency already administers both methods and could handle a shift to mandatory worldwide reporting with education and outreach, though revenue estimates are difficult because foreign affiliate information is not directly available.
Committee members asked about foreign government pushback, administrative burden, industries with more profit shifting, revenue uncertainty, and whether companies would leave California. LAO and FTB witnesses said pushback from foreign governments was plausible, but they did not expect major business flight because California’s tax is largely based on sales rather than physical presence. They also said worldwide reporting could reduce profit shifting but might increase revenue volatility and litigation risk. A second panel of academic and tax policy witnesses argued that Water’s Edge is a loophole that rewards aggressive tax planning, that worldwide combined reporting would better capture income tied to California, and that modern federal and international rules such as NCTI/GILTI, CAMT, and Pillar Two reduce compliance concerns and make a return to worldwide reporting more feasible. They also said California’s current system can create selection effects and may under-tax large multinationals.
In the next panel, a California Budget and Policy Center witness urged eliminating the Water’s Edge election, calling it a costly loophole that benefits large global corporations over smaller domestic businesses and deprives the state of billions in revenue that could support health care and other services. A Silicon Valley Leadership Group witness gave historical context for why Water’s Edge was adopted and began outlining concerns about compliance, double taxation, and the risk of overreaching beyond income truly connected to California. No bill was voted on or advanced; the hearing was informational only, with members using the testimony to weigh the policy trade-offs and possible transition periods if the Legislature were to change the current rules.
CA
California 2025-2026 Regular Session
Joint Hearing Assembly Revenue and Taxation Committee and Senate Revenue and Taxation Committee Feb 11th, 2026
Transcript Highlights:
- , plus controlled foreign corporations that have what is called subpart F income, as well as foreign
- It actually does contain nominally foreign-source income in the context of subpart F income.
- F income can be transformed into NICTI income, and NICTI income can be transformed to subpart F income
- , and we only include subpart F income.
- There's the subpart F question, for instance.
CA
California 2025-2026 Regular Session
Joint Hearing Assembly Revenue and Taxation Committee and Senate Revenue and Taxation Committee Feb 11th, 2026
Transcript Highlights:
- foreign corporations that have what is called subpart F income, as well as foreign corporations to the
- It actually does contain nominally foreign-source income in the context of subpart F income.
- F income can be transformed into NCTI income, and NCTI income can be transformed to subpart F income
- , and we only include subpart F income.
- There's the subpart F question, for instance.
Summary:
The joint informational hearing focused on California’s taxation of foreign subsidiaries of U.S. corporations, especially the state’s water’s-edge election versus worldwide combined reporting. Committee members and witnesses discussed how unitary taxation and sales-factor apportionment work, why multinational corporations are a small share of filers but a large share of tax liability, and how foreign income, profit shifting, and double taxation concerns affect policy choices. The Franchise Tax Board explained current filing rules, the seven-year water’s-edge election, and recent filing statistics showing about 21,562 water’s-edge returns in 2023, roughly 6% of C corporation filers but about half of corporate tax liability.
The Legislative Analyst’s Office and FTB staff emphasized that revenue effects from eliminating water’s edge are uncertain because foreign affiliate income is not directly observable, and they noted possible revenue volatility and administrative complexity. Several committee members asked about foreign government pushback, the burden on FTB, whether certain industries are more likely to shift profits, and whether companies would leave California; witnesses generally said there was no strong evidence that firms would exit the state because tax liability is driven mainly by California sales. They also discussed how California already administers both methods, how the election can be advantageous or disadvantageous depending on a firm’s facts, and how federal reforms like GILTI/NCTI, CAMT, and OECD Pillar Two may affect the issue.
The second panel presented sharply contrasting views. One professor and a tax policy advocate argued that water’s edge creates unfairness, encourages profit shifting, and leaves California with billions in lost revenue, while a Tax Foundation witness argued that mandatory worldwide reporting would tax the wrong income, create double taxation and litigation risk, and impose heavy compliance burdens, especially for foreign-based multinationals. A later panel from the California Budget and Policy Center supported closing the “water’s-edge loophole,” saying it would raise needed revenue for public services and level the playing field between large multinationals and smaller domestic businesses. No vote or formal action was taken; the hearing was informational only.
CA
California 2025-2026 Regular Session
Joint Hearing Senate Revenue and Taxation Committee and Assembly Revenue and Taxation Committee Feb 11th, 2026
Transcript Highlights:
- foreign corporations that have what is called subpart F income, as well as foreign corporations to the
- It actually does contain nominally foreign-source income in the context of subpart F income.
- F income can be transformed into NICTI income, and NICTI income can be transformed to subpart F income
- , and we only include subpart F income.
- There’s the subpart F question, for instance.
WA
Washington 2025-2026 Regular Session
Senate Transportation Feb 26th, 2026 at 08:00 am
Transportation
Transcript Highlights:
- Subpart six updates reporting deadlines for the SR 520 bridge noise study.
- Subpart six updates reporting deadlines for the SR 520 bridge noise study.
- There is Amendment F, offered by Senator Wilson as well.
- There is Amendment F, offered by There is Amendment F, offered by Senator Wilson as well.
- I move adoption of Amendment F by Senator Wilson.
Committee:
Senate Transportation
Keywords:
transportation budget, transportation appropriations, capital budget, supplemental budget, Washington State Department of Transportation, WSDOT, Washington State Patrol, Department of Licensing, ferries, Puget Sound ferries, tolling, express toll lanes, highway safety, traffic safety, impaired driving, ignition interlock, speed cameras, transit funding, public transit, multimodal transportation
US
US Federal 2025-2026 Regular Session
US House Floor Proceedings (Monday, April 28, 2025)
US Federal House Floor Meeting
Transcript Highlights:
- c><02:55:29.279><c> playing</c><02:55:29.520><c> field</c><02:55:29.840><c> so</c><02:55:30.080><c> f<
- /c><02:55:30.640><c> so</c><02:55:30.880><c> more</c> level the playing field so f so more level the
- playing field so f so more fans<02:55:32.080><c> have</c><02:55:32.399><c> f</c><02:55:32.560><c> a</
- fair</c><02:55:33.120><c> shot</c><02:55:33.359><c> at</c><02:55:33.680><c> attending</c> fans have f
- . incomes. incomes.
Bills:
SB146 , HR973 , HR859 , HR906 , HB2449 , HB2399 , HR866 , HB2482 , HB2444 , HB2458 , HB1721 , HB2480 , HB1479 , HB1442 , HR1402 , HR617 , HR452
Keywords:
nonconsensual, visual depictions, digital forgery, intimate content, online platforms, privacy, protection, harm prevention, John F. Kennedy Center, Donald J. Trump, Federal arts funding, memorial designation, cultural institutions, Congressional authority, public arts programs, Hampden-Sydney College, anniversary, higher education, civic responsibility, liberal arts
WA
Washington 2025-2026 Regular Session
Senate Transportation Feb 26th, 2026
Transcript Highlights:
- Subpart nine Subpart nine specifies that $3.174 million of the transportation and proven board bond retirement
- Subpart three clarifies the scope of the uninsured Subpart three clarifies the scope of the uninsured
- There is Amendment F, offered by Senator Wilson as well.
- There is Amendment F, offered by Senator Wilson as well.
- Chairman, I move adoption of Amendment F by Senator Wilson.
Summary:
The Senate Transportation Committee met in executive session to brief and act on three measures: proposed substitute Senate Bill 6005, the 2006 supplemental transportation budget; proposed substitute Senate Bill 6225, authorizing transportation bonds; and engrossed substitute House Bill 2508, relating to the Office of Independent Investigations. Staff first reviewed eight amendments to SB 6005, including technical corrections and several funding changes for ferry service, rail projects, transit electrification, and other transportation programs. The committee then adopted all eight amendments, rolled them into the bill, and advanced SB 6005 with a due-pass recommendation to the Rules Committee.
For SB 6225, staff explained that the bill would authorize additional transportation bonds, including $1.1 billion in general bonds backed by gas tax and vehicle-related revenues, $400 million for potential cost increases on Move Ahead Washington projects, and a $500 million increase in SR 520 bond authorization, while repealing some older bond authority. With no amendments offered, the committee advanced the bill with a due-pass recommendation to the Rules Committee.
The committee also considered engrossed substitute House Bill 2508, which would clarify the scope of authority of the Office of Independent Investigations and add public disclosure and privacy provisions. The committee moved the bill without recommendation to the Ways and Means Committee. Members concluded by thanking staff for their work on the budget and bond package before adjourning.
ID
Transcript Highlights:
- group, communities that have both a high rate burden and low income.
- of their household income, and then also other pressures associated with that.
- But the tier one is your median household income. ...to push those together.
- Tier one is your median household income at or below the statewide median household income.
- MHI. ...income is less than, say, 80% of the statewide MHI.
Committee:
Senate Resources and Environment
NM
New Mexico 2025 Regular Session
IC - Revenue Stabilization and Tax Policy Aug 14th, 2025
Revenue Stabilization & Tax Policy Committee
Transcript Highlights:
- So net income is then base income with the adjustments, and taxable income is net income with adjustments
- Base income equals federal taxable income.
- Net income means base income combined.
- Sourcing rules for certain kinds of income called subpart F income.
- So, there's part of subpart F income that is investment income in New Mexico conforms.
TX
Transcript Highlights:
- These fees disproportionately affect low-income households and can lead to service shutoffs.
- This Camp Longhorn location is located right next to the proposed rock-crushing quarry off of F.
Bills:
HB1520 , HB1525 , HB1530 , HB1535 , HB2068 , HB2091 , HB2347 , HB2372 , HB2805 , HB2815 , HB2867 , HB3154 , HB3482 , HB3483 , HB3663 , HB3781 , HB3901 , HB3915 , HB4135 , HB4153 , HB4158 , HB4329 , HB4331
Committee:
House Natural Resources
Keywords:
Angelina and Neches River Authority, river authority, Sunset Advisory Commission, Texas Sunset Act, Special District Local Laws Code, local government, natural resources, board of directors, director training, board governance, public testimony, open meetings, public information, conflict of interest, ethics, complaint system, general manager, board president, staggered terms, removal of director
TX
Bills:
HB1520 , HB1525 , HB1530 , HB1535 , HB2068 , HB2091 , HB2347 , HB2372 , HB2805 , HB2815 , HB2867 , HB3154 , HB3482 , HB3483 , HB3663 , HB3781 , HB3901 , HB3915 , HB4135 , HB4153 , HB4158 , HB4329 , HB4331
Committee:
House Natural Resources
Keywords:
Angelina and Neches River Authority, river authority, Sunset Advisory Commission, Texas Sunset Act, Special District Local Laws Code, local government, natural resources, board of directors, director training, board governance, public testimony, open meetings, public information, conflict of interest, ethics, complaint system, general manager, board president, staggered terms, removal of director