Bill > S2033

This bill addresses offshore tax avoidance by modifying how certain income from foreign subsidiaries is treated for tax purposes in Massachusetts. Specifically, the bill focuses on changes related to sections 951 and 951A of the Internal Revenue Code, which deal with income from controlled foreign corporations. The legislation makes several key modifications to existing tax law: it ensures that income included under section 951A of the Code is not treated as dividends for tax calculation purposes, allows a deduction of 50% for amounts included in federal gross income under section 951A, and updates various provisions in the state's tax code to consistently handle these international income provisions. The bill applies to all tax years beginning on or after January 1, 2025, which suggests it is designed to close potential tax loopholes that allow corporations to minimize their state tax liability through offshore income strategies. By making these changes, the bill aims to create more progressive revenue collection and prevent corporations from using complex international tax structures to reduce their state tax burden.

Budget and Finance

https://malegislature.gov/Bills/194/S2033