Technical Information Release  Working Draft TIR: Massachusetts Conformity to Certain Provisions in Public Law No. 119-21

Date:	10/21/2025
Referenced Sources:	Massachusetts General Laws

This Technical Information Release (“TIR”) provides information on whether the Massachusetts income tax imposed by G.L. c. 62 and the net income measure of the Massachusetts corporate excise (the “Massachusetts corporate excise”) imposed by G.L. c. 63 conform to certain provisions of federal Public Law No. 119-21 (the “Act”).^[1]  The Act amended numerous Internal Revenue Code (“Code”) sections affecting the computation of federal gross income and deductions of various taxpayers, including individuals, trusts, estates, unincorporated businesses, and corporations.  The Massachusetts income tax generally determines Massachusetts gross income based on the Code as amended and in effect on January 1, 2024, but conforms to the Code as currently in effect for the determination of trade or business expense deductions, with limited exceptions, and certain other specified Code sections.^[2]  The Massachusetts corporate excise automatically conforms to the current Code in determining both Massachusetts gross income and deductions, with limited exceptions.^[3]    

Further guidance on Massachusetts conformity with the Act’s provisions may be issued as needed.

The following chart lists the Act’s provisions that principally affect federal gross income or federal deductions and whether the Massachusetts income tax and the Massachusetts corporate excise conform to such provisions.  The Act’s provisions that amend Code sections that do not impact the determination of the Massachusetts income tax or Massachusetts corporate excise, such as federal tax rates and credits, are not included. 

Act Section	Massachusetts Income Tax Conformity	Massachusetts Corporate Excise Conformity
Sec. 70105. Extension and enhancement of deduction for qualified business income.	No	N/A*
Sec. 70108. Extension and modification of limitation on deduction for qualified residence interest.	No	N/A
Sec. 70109. Extension and modification of limitation on casualty loss deduction.	No	N/A
Sec. 70110. Termination of miscellaneous itemized deductions other than educator expenses.	No	N/A
Sec. 70112. Extension and modification of qualified transportation fringe benefits.	No	N/A
Sec. 70113. Extension and modification of limitation on deduction and exclusion for moving expenses.	No	N/A
Sec. 70114. Extension and modification of limitation on wagering losses.	Yes	Yes
Sec. 70115. Extension and enhancement of increased limitation on contributions to ABLE accounts.	Yes	N/A
Sec. 70117. Extension of rollovers from qualified tuition programs to ABLE accounts permitted.	Yes	N/A
Sec. 70118. Extension of treatment of certain individuals performing services in the Sinai Peninsula and enhancement to include additional areas.	No	N/A
Sec. 70120. Limitation on individual deductions for certain state and local taxes, etc.	No	N/A
Sec. 70201. No tax on tips.	No	N/A
Sec. 70202. No tax on overtime.	No	N/A
Sec. 70203. No tax on car loan interest.	No	N/A
Sec. 70204. Trump accounts and contribution pilot program.	No	N/A
Sec. 70301. Full expensing for certain business property.	No	No
Sec. 70302. Full expensing of domestic research and experimental expenditures.	Yes	Yes
Sec. 70303. Modification of limitation on business interest.	Yes	Yes
Sec. 70305. Exceptions from limitations on deduction for business meals.	Yes	Yes
Sec. 70306. Increased dollar limitations for expensing of certain depreciable business assets.	Yes	Yes
Sec. 70307. Special depreciation allowance for qualified production property.	Yes	Yes
Sec. 70311. Modifications related to foreign tax credit limitation.	No	No
Sec. 70312. Modifications to determination of deemed paid credit for taxes properly attributable to tested income.	No	No
Sec. 70313. Sourcing certain income from the sale of inventory produced in the United States.	No	No
Sec. 70321. Modification of deduction for foreign-derived deduction eligible income and net CFC tested income.	No	No
Sec. 70322. Determination of deduction eligible income.	No	No
Sec. 70323. Rules related to deemed intangible income.	Yes	Yes
Sec. 70341. Coordination of business interest limitation with interest capitalization provisions.	Yes	Yes
Sec. 70342. Definition of adjusted taxable income for business interest limitation.	Yes	Yes
Sec. 70351. Permanent extension of look-thru rule for related controlled foreign corporations.	Yes	Yes
Sec. 70352. Repeal of election for 1-month deferral in determination of taxable year of specified foreign corporations.	Yes	Yes
Sec. 70353. Restoration of limitation on downward attribution of stock ownership in applying constructive ownership rules.	Yes	Yes
Sec. 70354. Modifications to pro rata share rules.	Yes	Yes
Sec. 70404. Enhancement of the dependent care assistance program.	No	N/A
Sec. 70412. Exclusion for employer payments of student loans.	No	N/A
Sec. 70413. Additional expenses treated as qualified higher education expenses for purposes of 529 accounts.	Yes	N/A
Sec. 70414. Certain postsecondary credentialing expenses treated as qualified higher education expenses for purposes of 529 accounts.	Yes	N/A
Sec. 70421. Permanent renewal and enhancement of opportunity zones.	Yes	Yes
Sec. 70424. Permanent and expanded reinstatement of partial deduction for charitable contributions of individuals who do not elect to itemize.	No	N/A
Sec. 70425. 0.5 percent floor on deduction of contributions made by individuals.	No	N/A
Sec. 70426. 1-percent floor on deduction of charitable contributions made by corporations.	N/A	Yes
Sec. 70430. Exception to percentage of completion method of accounting for certain residential construction contracts.	Yes	Yes
Sec. 70431. Expansion of qualified small business stock gain exclusion.	No	N/A
Sec. 70434. Treatment of certain qualified sound recording productions.	Yes	Yes
Sec. 70435. Exclusion of interest on loans secured by rural or agricultural real property.	No	Yes
Sec. 70438. Extension of rules for treatment of certain disaster-related personal casualty losses.	No	N/A
Sec. 70439. Restoration of taxable REIT subsidiary asset test.	Yes	Yes
Sec. 70507. Termination of energy efficient commercial buildings deduction.	Yes	Yes
Sec. 70509. Termination of cost recovery for energy property.	Yes	Yes
Sec. 70524. Income from hydrogen storage, carbon capture, advanced nuclear, hydropower, and geothermal energy added to qualifying income of certain publicly traded partnerships.	Yes	Yes
Sec. 70601. Modification and extension of limitation on excess business losses of noncorporate taxpayers.	No	N/A
Sec. 70603. Excessive employee remuneration from controlled group members and allocation of deduction.	Yes	Yes

*”N/A”, or “not applicable,” indicates a provision does not apply to income taxpayers or corporate excise taxpayers, as indicated.
 

WORKING DRAFT FOR PUBLIC COMMENT - 10/21/25

 

[1] See Public Law No. 119-21, also known as the “One Big Beautiful Bill Act,” signed into law on July 4, 2025.

[2] M.G.L. c. 62, § 1(c).

[3] M.G.L. c. 63, § 30.3, 30.4.