SB 1590 Summary

• Establishes a combined "water's edge group" reporting method for related corporations, requiring them to file a single Florida corporate income tax return instead of separate returns, effective for tax years beginning January 1, 2013.

• Defines "tax haven" jurisdictions based on OECD criteria and exemptions from taxation, and permits corporations conducting 80% or more of business outside the U.S. to exclude themselves from water's edge group membership unless incorporated in a tax haven.

• Limits deductions for net operating losses, capital losses, and excess contributions to members of water's edge groups that are United States members, and requires subtraction of intercompany dividends to prevent double taxation.

• Repeals the prior affiliated group consolidated return provisions under section 220.131 and requires computational schedules and domestic disclosure spreadsheets with water's edge group returns to detail income allocation and apportionment to various states.

• Eliminates affiliated group provisions from multiple tax credit sections (community contribution, contaminated site rehabilitation, renewable energy, capital investment, and entertainment industry incentives) and requires recaptured funds to be deposited in the General Revenue Fund.