Corporate Fair Share

What is Corporate Fair Share / GILTI?

Massachusetts has the opportunity to make our tax structure fairer for small, local businesses AND generate hundreds of millions annually for the Commonwealth. The state could reclaim hundreds of millions of tax dollars a year by adopting the federal approach to the GILTI (Global Intangible Low-Taxed Income) provision.

The GILTI provision identifies U.S. profits shifted by multinational corporations to overseas tax havens, like the Cayman Islands, and includes a portion of those shifted profits in tax calculations.

A bill is currently being considered by the Massachusetts legislature to prevent corporate tax avoidance by multinational corporations: An Act combatting offshore tax avoidance (HB3110/SB2033).

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Testimony in support of An Act combatting offshore tax avoidance

MassBudget urges the Joint Committee on Revenue to report H.3110 and S.2033 out favorably. This legislation would allow Massachusetts to collect corporate income tax revenue currently lost to abusive, international profit-shifting by large, multinational corporations. The result would generate hundreds of millions of dollars annually to address critical needs of communities throughout the Commonwealth.

Due to Single Sales Factor Apportionment, Multinational Corporations Cannot Dodge State Taxes by Reducing Workforce or Capital Investments in Massachusetts

Moving operations or employees out of Massachusetts won’t reduce a corporation’s taxes on its profits by a single dollar, because the share of corporate profits taxed by the Commonwealth depends only on the share of a corporation's sales made to Massachusetts customers.

PolicyTALKS – GILTI / Corporate Fair Share

On May 13th, 2025, MassBudget hosted our first PolicyTALKS event. Researchers, advocates, and policymakers explored how to improve corporate tax fairness and build a stronger Massachusetts.

Estimate of Potential GILTI Revenue

Building off of a recent analysis performed by the Institute on Taxation and Economic Policy (ITEP), MassBudget estimates that adopting a robust and well-enforced provision requiring multinational corporations to include 50 percent of GILTI (Global Intangible Low-Taxed Income) in their state tax calculations would generate over $400 million a year for the Commonwealth.

By Taxing GILTI Profits, Massachusetts Can Reclaim Millions in Revenue Lost to Corporate Offshore Tax Dodging

Changing the state approach to Global Intangible Low-Taxed Income would allow the Commonwealth to reclaim a sizable share of the tax revenue lost to international profit-shifting - allowing for transformative investments and a cushion against the impact of potential federal cuts.
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