SB67 Summary

• Requires related entities engaged in a unitary business to file a single combined corporate income tax return instead of separate returns, beginning with tax years after December 31, 2017.

• Adds definitions for "combined group," "unitary business," and "tax haven" to identify which corporations must be included in combined reporting based on economic interdependence and integration.

• Provides optional "water's-edge" and "affiliated group" elections allowing taxpayers to limit combined reporting to U.S. operations or affiliated group members, subject to specific criteria and 10-year binding periods.

• Specifies detailed rules for determining combined group taxable income, including provisions for intercompany transactions, dividend eliminations, capital gains treatment, and apportionment factors across all group members.

• Grants the Department of Revenue broad discretion to require combined reporting when necessary to prevent tax avoidance and authority to promulgate rules facilitating transition from separate entity to combined reporting.