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HOUSE DOCKET, NO. 3390 FILED ON: 1/17/2025
HOUSE . . . . . . . . . . . . . . . No. 3110
The Commonwealth of Massachusetts
_________________
PRESENTED BY:
Carlos González
_________________
To the Honorable Senate and House of Representatives of the Commonwealth of Massachusetts in General
Court assembled:
The undersigned legislators and/or citizens respectfully petition for the adoption of the accompanying bill:
An Act combating offshore tax avoidance.
_______________
PETITION OF:
NAME:DISTRICT/ADDRESS :DATE ADDED:Carlos González10th Hampden1/17/2025Steven Owens29th Middlesex1/23/2025Sean Reid11th Essex1/23/2025Carmine Lawrence Gentile13th Middlesex1/23/2025Lindsay N. Sabadosa1st Hampshire1/23/2025Jason M. LewisFifth Middlesex1/23/2025Rodney M. Elliott16th Middlesex1/23/2025Natalie M. Higgins4th Worcester1/27/2025Bud L. Williams11th Hampden1/27/2025Danillo A. Sena37th Middlesex1/27/2025James B. EldridgeMiddlesex and Worcester1/27/2025James K. Hawkins2nd Bristol1/27/2025Samantha Montaño15th Suffolk1/27/2025Margaret R. Scarsdale1st Middlesex1/27/2025Christine P. Barber34th Middlesex1/28/2025Tara T. Hong18th Middlesex1/29/2025Erika Uyterhoeven27th Middlesex1/30/2025Kenneth I. Gordon21st Middlesex1/30/2025 2 of 2
Alan Silvia7th Bristol1/30/2025Michael D. BradySecond Plymouth and Norfolk1/30/2025Rebecca L. RauschNorfolk, Worcester and Middlesex1/30/2025Mike Connolly26th Middlesex2/11/2025David Henry Argosky LeBoeuf17th Worcester2/11/2025Antonio F. D. Cabral13th Bristol2/11/2025James C. Arena-DeRosa8th Middlesex2/12/2025Christopher Hendricks11th Bristol2/14/2025Daniel Cahill10th Essex2/14/2025Marjorie C. Decker25th Middlesex2/14/2025Patricia A. Duffy5th Hampden2/18/2025John Francis Moran9th Suffolk2/20/2025Brian W. Murray10th Worcester2/21/2025Natalie M. Blais1st Franklin2/24/2025Colleen M. Garry36th Middlesex2/26/2025Frank A. Moran17th Essex2/26/2025Kevin G. Honan17th Suffolk2/26/2025Tricia Farley-Bouvier2nd Berkshire2/27/2025Adam J. Scanlon14th Bristol2/27/2025Paul McMurtry11th Norfolk3/3/2025Jennifer Balinsky Armini8th Essex3/3/2025Steven Ultrino33rd Middlesex3/4/2025Mary S. Keefe15th Worcester3/7/2025Thomas W. MoakleyBarnstable, Dukes and Nantucket3/7/2025Christopher J. Worrell5th Suffolk3/7/2025Adrianne Pusateri Ramos14th Essex3/7/2025Jack Patrick Lewis7th Middlesex3/7/2025Tommy Vitolo15th Norfolk3/10/2025Mindy Domb3rd Hampshire3/10/2025Manny Cruz7th Essex3/11/2025Patrick Joseph Kearney4th Plymouth3/11/2025William F. MacGregor10th Suffolk3/12/2025 1 of 3
HOUSE DOCKET, NO. 3390 FILED ON: 1/17/2025
HOUSE . . . . . . . . . . . . . . . No. 3110
By Representative González of Springfield, a petition (accompanied by bill, House, No. 3110) of
Carlos González and others relative to offshore taxes. Revenue.
The Commonwealth of Massachusetts
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In the One Hundred and Ninety-Fourth General Court
(2025-2026)
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An Act combating offshore tax avoidance.
Be it enacted by the Senate and House of Representatives in General Court assembled, and by the authority
of the same, as follows:
1 SECTION 1. Subsection (e) of section 1 of chapter 62 of the General Laws, as appearing
2in the 2022 Official Edition, is hereby amended by striking the second sentence and replacing it
3with the following sentence:-
4 Amounts included in federal gross income pursuant to section 951 of the Code shall be
5treated as dividends under this chapter; provided that amounts included in federal gross income
6pursuant to section 951A of the Code shall not be treated as dividends.
7 SECTION 2. Subsection (a) of Part B. of section 3 of said chapter 62 of the General
8Laws is hereby amended by inserting at the end thereof the following:-
9 (20) An amount equal to fifty percent of amounts included in federal gross income
10pursuant to section 951A of the Code. 2 of 3
11 SECTION 3. The definition of “Net income” in section 1 of chapter 63 of the General
12Laws, as most recently amended by chapter 273 of the Acts of 2018, is hereby amended by
13striking the sixth sentence and replacing it with the following sentence:-
14 For purposes of this definition, amounts included in federal gross income pursuant to
15section 951 of the Code shall be treated as dividends; provided that amounts included in federal
16gross income pursuant to section 951A of the Code shall not be treated as dividends.
17 SECTION 4. Said definition of “Net income” in said section 1 of said chapter 63 of the
18General Laws, as so amended, is hereby further amended by striking subsection (g) and replacing
19it with the following subsection:-
20 (g) the deductions allowed by sections 245A, 250 and 965(c) of the Code; provided,
21however, that a deduction shall be allowed for an amount equal to fifty percent of amounts
22included in federal gross income pursuant to section 951A of the Code.
23 SECTION 5. Section 2A of said chapter 63 of the General Laws, as so amended, is
24hereby amended by striking subsection (h) and replacing it with the following subsection:-
25 (h) For purposes of this section, dividends that are deemed to be received from an entity,
26including amounts included in federal gross income pursuant to section 951 of the Code, shall
27not be considered receipts, and amounts included in federal gross income pursuant to section
28951A of the Code also shall not be considered receipts.
29 SECTION 6. Paragraph 4 of section 30 of said chapter 63, as so amended, is hereby
30amended by striking the fourth sentence and replacing it with the following sentence:- 3 of 3
31 For purposes of this section and subsection (a) of section 38, amounts included in federal
32gross income pursuant to section 951 of the Code shall be treated as dividends; provided that
33amounts included in federal gross income pursuant to section 951A of the Code shall not be
34treated as dividends.
35 SECTION 7. Said paragraph 4 of said section 30 of said chapter 63, as so amended, is
36hereby further amended by striking clause (viii) and replacing it with the following clause:-
37 (viii) the deductions allowed by sections 245A, 250 and 965(c) of the Code; provided,
38however, that a deduction shall be allowed for an amount equal to fifty percent of amounts
39included in federal gross income pursuant to section 951A of the Code.
40 SECTION 8. Subsection (f) of section 38 of said chapter 63, as so amended, is hereby
41amended by inserting, in line 136, after the word “dividends”, the following:- , amounts included
42in federal gross income pursuant to section 951A of the Code,
43 SECTION 9. The provisions of this Act shall apply to all tax years beginning on or after
44January 1, 2025.