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Multistate expert urges Vermont to consider taxing full NCTI (formerly GILTI) with apportionment
Ways and Means Committee · February 6, 2026
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Summary
A Multistate Tax Commission witness recommended Vermont consider including 100% of NCTI in its tax base while using apportionment to avoid overtaxing foreign-source income; the tax department cautioned that such a move would carry revenue and administrative trade-offs.
A witness from the Multistate Tax Commission recommended that Vermont examine whether to include the full amount of NCTI (the HR1 successor to GILTI) in its state tax base while continuing to use apportionment formulas to avoid taxing income earned outside Vermont.
"What I would propose in my own name...is that…
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