HB 999 - Corporate Income Tax Summary

• Establishes "water's edge group" combined reporting method for multistate/multinational corporations, requiring all commonly-owned corporations with integrated business activities to file combined Florida corporate income tax returns beginning January 1, 2022.

• Creates new definitions including "tax haven" (jurisdictions with no/nominal taxes, lack transparency, or facilitate foreign entities without substantive presence) and "water's edge reporting method" to determine taxable income of affiliated corporate groups.

• Prohibits certain deductions and limits carryovers for water's edge group members, including restrictions on net operating losses and capital losses for non-U.S. members; requires subtraction of dividends paid between group members to prevent double taxation.

• Requires water's edge group returns to include computational schedules showing federal income, intercompany eliminations, Florida adjustments, and apportionment factors, plus a domestic disclosure spreadsheet with income by state and tax liabilities.

• Provides effective date of July 1, 2021 with transition period through January 1, 2022; directs any additional revenue to reduce commercial real property rental tax rate under section 212.031.