MN HF4535

Requires the Minnesota Department of Revenue commissioner to submit a report by January 1, 2025 to legislative tax committee chairs and ranking minority members on corporate tax base erosion in the state.

Report must analyze international corporate structures and transactions that reduce income apportionable to Minnesota, including estimates of revenue impact and methods for calculating Minnesota's share of shifted profits.

Report must evaluate the state's current treatment of income under Internal Revenue Code section 951A and examine other options for modifying corporate franchise tax, specifically including worldwide combined reporting.

For worldwide combined reporting, report must address how increased income apportioned to Minnesota would offset shifted profits, administrative impacts on taxpayers and the Department of Revenue, and recommendations for administrative changes.

Report must analyze litigation risks, including federal constitutional claims, associated with various tax base erosion approaches and provide recommendations to mitigate those risks.