The Tax Cuts and Jobs Act included significant changes to the manner in which foreign-sourced income is taxed. The Michigan Department of Treasury (the "Department"), like other state taxing authorities, was required to interpret how these federal changes would impact Michigan taxpayers. In a notice dated July 2, 2018, the Department provided its initial guidance regarding Michigan's interpretation of three of the more significant changes in federal tax law. The Department also noted that its interpretations are subject to potential changes as federal law is modified or clarified by Congress, the United States Treasury Department, and the Internal Revenue Service.

The table below summarizes the Department's interpretations of (1) the foreign income repatriation requirements set forth in section 965 of the Internal Revenue Code of 1986, as amended (Code), (2) the base erosion and anti-abuse tax (BEAT), and (3) the global intangible low-taxed income (GILTI) provisions set forth in Code section 951A.