Corporate Tax Policy: Chamber to push for additional revisions to combined reporting regulation

Corporate Tax Policy: Chamber to push for additional revisions to combined reporting regulation

The Department of Revenue (DOR) released its combined reporting corporate tax regulation on May 26th. Although the regulations include a Chamber-backed revision, they also contain rules that will make it more difficult for multinational companies to compete in Massachusetts. Key parts of the regulation include:

• Disallowance of certain deductions for companies subject to a "foreign income inclusion" provision. Among those disallowed deductions are certain interest expenses from intercompany borrowing – a policy that will make it more difficult to raise capital.
  
• Limiting the intercompany inclusion provision to the inclusion of income, not losses, from intercompany transactions – the result of which is to prevent gross income included in a combined group’s taxable income from being reduced below zero even if a group’s member loses money in a year.
  
• A Chamber-backed revision stating that DOR would not seek to disregard an otherwise proper election that results in a reduction of Massachusetts tax liability – a change that more accurately reflects the legislative intent of the 10-year affiliated group election lock.

In the weeks ahead the Chamber will continue to work for improvements to these rules, through the regulatory process, the legislative process, or both.

View the Chamber's complete policy agenda here.