Unitary group expansion to foreign corporations provision

SF 3401 expands Minnesota's unitary tax system to include foreign corporations, meaning foreign-owned corporate groups operating in Minnesota will now be treated as a single entity for state tax purposes. The bill adds a tax subtraction for global intangible low-taxed income (GILTI), which is income from foreign subsidiaries subject to a federal minimum tax under U.S. law. These changes apply to taxable years beginning after December 31, 2025. The bill directly affects foreign corporations with Minnesota operations that are part of multinational groups subject to unitary taxation.