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MA S2033
Bill
AI Summary
- Amends Massachusetts tax law to treat Global Intangible Low-Taxed Income (GILTI) under IRC Section 951A differently from Subpart F income under IRC Section 951, preventing GILTI from being classified as dividends for state tax purposes
- Allows a 50% deduction for GILTI amounts included in federal gross income, effectively taxing only half of this offshore income at the state level
- Disallows federal deductions under IRC Sections 245A, 250, and 965(c) for Massachusetts tax purposes, except for the new 50% GILTI deduction
- Excludes GILTI amounts from the receipts factor used in corporate tax apportionment calculations
- Applies to all tax years beginning on or after January 1, 2025
Legislative Description
Combating offshore tax avoidance
Last Action
Hearing rescheduled to 10/03/2025 from 10:00 AM-12:35 PM in Gardner Auditorium Hearing updated to New End Time
10/3/2025
Committee Referrals
Revenue2/27/2025
Full Bill Text
No bill text available