An Act combating offshore tax avoidance

HD 3390 modifies Massachusetts tax law to address income from foreign entities. It specifies that amounts included in federal income under Section 951A of the IRS Code (related to global intangible low-taxed income) will no longer be treated as dividends for state tax purposes, and taxpayers can only deduct 50% of this income instead of the full amount. This primarily affects businesses and individuals with foreign income subject to Section 951A provisions. The changes apply to tax years beginning on or after January 1, 2025.