FL S0238

Establishes "unitary combined reporting" for corporate income tax, requiring corporations with integrated business activities and common ownership (50% or more voting stock control) to file a single combined return and calculate taxes as a unified group rather than separately

Repeals the existing consolidated return provisions under s. 220.131 and replaces them with new unitary combined group requirements, where all members must combine their adjusted federal income and apportionment factors

Requires unitary combined groups to file a computational schedule showing combined income, intercompany eliminations, and apportionment calculations, plus a domestic disclosure spreadsheet reporting income and tax liability to each state

Prohibits deductions for net operating losses, capital loss carryovers, excess charitable contributions, and certain employee plan contributions for non-U.S. members of a unitary combined group

Takes effect July 1, 2026, with transitional rules requiring all affiliated groups previously filing consolidated returns and all unitary combined group members to begin filing combined returns for taxable years beginning on or after January 1, 2027