Illinois General Assembly
Two bills were introduced today - one in the House and one in the Senate - that appear to have the effect of making world-wide combination, for purposes of apportioning the income of a unitary business group, the default position in Illinois.
The bills amend IITA Section 304 to authorize a water's edge election. The water's edge election would also include the entire income and apportionment factors of any member of a unitary business group doing business in a so-called tax haven. The bills contains a list of tax havens.
To move towards world-wide combination as the default position, the definition of unitary business group in IITA Section 1501 is modified and includes a repeal the 80-20 rule.
The legislation also provides that the foreign dividend deduction in the case of a water's edge election is limited to 75%
The bills were introduced this afternoon, so I haven't had an opportunity to discuss the bills with the sponsors. However, I am taking these proposals seriously because of who is sponsoring the legislation. Representative Greg Harris is the House Majority Leader and Senator Heather Steans is the Chairperson of the Appropriations I committee.
Your thoughts and comments as to the impact of this legislation will be helpful and greatly appreciated as we gear up to fight this legislation. Please contact me at your convenience either by my cell phone (217) 741-1384 or email email@example.com.
I will update you as a receive more information.