SB351 Summary

• Defines "unitary business" as a single economic enterprise made up of separate parts of a single business entity or commonly controlled group of business entities that are sufficiently interdependent, integrated, and interrelated to provide synergy and mutual benefit.

• Requires the Alabama Department of Revenue Commissioner to mandate Alabama taxpayers that are part of a unitary business consisting of multiple business entities to file a combined report to determine their Alabama taxable income.

• Combined report must include all unitary business members doing business in the United States or commercially domiciled in non-U.S. jurisdictions designated as tax havens by the Organization for Economic Cooperation and Development (OECD).

• Taxpayers shall calculate Alabama taxable income by apportioning the combined group's income to Alabama using a formula measuring the taxpayer's Alabama source apportionment data relative to the combined group's apportionment data from all sources.

• Commissioner shall promulgate regulations providing details of combined report calculations and enforcement procedures.

• Effective date is the first day of the third month following passage and gubernatorial approval or becoming law.