Income/Franchise:
Montana DOR Proposes Rule Changes Reflecting Elimination of Tax Haven Jurisdictions List
MAR Notice No. 42-1077: Proposed Amended ARM 42.26.311 and Proposed Repeal of ARM 42.26.306, Mont. Dept. of Rev. (4/16/24). The Montana Department of Revenue proposed rule changes reflecting state corporate income tax legislation enacted in 2023 [see S.B. 246 (2023) and State Tax Matters, Issue 2023-21, for more details on this legislation] which removed “tax haven” corporations from the water’s-edge group of affiliated corporations effective for tax periods beginning after December 31, 2022. The rule proposal reflects how C corporations in a unitary relationship with a taxpayer incorporated in a previously designated tax haven no longer need to have their income and apportionment factors included in the water’s-edge combined filing group. A related public hearing is scheduled for May 21, 2024, and any comments on the proposed changes are due by May 28, 2024. Please contact us with any questions.
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