HF1649 (Legislative Session 94 (2025-2026))

Corporate franchise and unitary taxation; foreign corporations required to be treated as unitary with a shareholder.

AI Generated Summary

Purpose of the Bill

The bill aims to adjust taxation rules for corporations in Minnesota, particularly focusing on how foreign corporations are taxed when they are connected to a unitary business group with Minnesota operations.

Main Provisions

  • Unitary Taxation of Foreign Corporations: The bill proposes that foreign corporations should be treated as part of a unitary business group if they have ties to shareholders within that group. This means that their income would be considered together with the entire group for tax purposes.

  • Global Intangible Low-Taxed Income (GILTI): The bill makes changes related to GILTI. Specifically, it adds a provision to allow the subtraction of GILTI from the income of corporations, aligning with section 951A of the Internal Revenue Code.

Significant Changes to Existing Law

  • This bill amends existing Minnesota Statutes by adding subdivisions to sections 290.0132, 290.0134, and 290.17, which affects the treatment of corporate income connected to foreign entities.

  • It repeals Minnesota Statutes 2024, section 290.21, subdivision 10, potentially removing or revising existing rules related to corporate taxation.

Relevant Terms

global intangible low-taxed income, unitary taxation, foreign corporations, corporate franchise tax, Internal Revenue Code.

Bill text versions

Actions

DateChamberWhereTypeNameCommittee Name
February 26, 2025HouseFloorActionIntroduction and first reading, referred toTaxes