MN SF3401

Expands Minnesota's unitary business tax group to include foreign corporations and foreign entities, requiring their worldwide income to be subject to apportionment for state tax purposes, effective for taxable years beginning after December 31, 2025.

Creates new subtractions from net income for global intangible low-taxed income (GILTI) under IRC Section 951A and Subpart F income under IRC Section 951, applicable to both corporations and individuals.

Allows the Commissioner of Revenue to require foreign corporations to use profit and loss statements conforming to GAAP or SEC filings if federal taxable income determination is not administrable, including translation and currency conversion requirements.

Requires disqualified captive insurance companies to be included in unitary combined reports, reversing the previous exclusion of foreign corporations from combined reporting.

Repeals Minnesota Statutes section 290.21, subdivisions 9 and 10, which treated controlled foreign corporation income and GILTI as dividend income for deduction purposes.