ME LD1939

Requires worldwide combined income reporting for unitary businesses with members reporting over $1 billion in gross revenues, subject to the federal corporate alternative minimum tax, or in scope under OECD Pillar Two rules

All members of a unitary business must file a combined return including income and apportionment factors for all entities worldwide, with members jointly and severally liable for the combined group's tax liability

Eliminates deductions for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) from the definition of taxable income to prevent offshore profit shifting

Taxpayers not meeting the $1 billion threshold may elect worldwide combined reporting for a minimum of 10 consecutive years; those not electing must apportion 50% of their GILTI income to the U.S.

Applies to tax years beginning on or after January 1, 2027