Senate Bill 7048 (2026) — Internal Revenue Code
SB 7048
Florida Bills
Florida Senate - 2026 SB 7048 By the Committee on Finance and Tax 593-03230-26 20267048__ Page 1 of 10 CODING: Words stricken are deletions; words underlined are additions. A bill to be entitled 1
An act relating to the Internal Revenue Code; amending 2 s. 220.03, F.S.; revising the date of adoption of the 3 Internal Revenue Code and other federal income tax 4 statutes for purposes of the state corporate income 5 tax; prohibiting retroactivity of certain Internal 6 Revenue Code amendments; specifying that a limitation, 7 a deduction, an expense, or an amortization may only 8 affect the computation of certain taxable income 9 beginning after a specified date; providing an 10 exception; specifying that certain provisions of the 11 Internal Revenue Code are disregarded for certain 12 taxable years; requiring taxpayers to add to and 13 deduct from taxable income in a specified manner; 14 amending s. 220.13, F.S.; revising adjustments 15 taxpayers must make to adjusted federal income with 16 respect to certain tax benefits; authorizing the 17 Department of Revenue to adopt rules; providing 18 retroactive operation; authorizing the department to 19 adopt emergency rules; providing that such emergency 20 rules are effective for a specified period of time; 21 providing that such emergency rules may be renewed 22 under certain circumstances; providing an expiration 23 date; providing an effective date. 24 25 Be It Enacted by the Legislature of the State of Florida: 26 27
Section 1. Paragraph (
n) of subsection (1) and paragraph 28 (
c) of subsection (2) of
section 220.03, Florida Statutes, are 29
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 2 of 10 CODING: Words stricken are deletions; words underlined are additions. amended, and subsection (6) is added to that section, to read: 30 220.03
Definitions.— 31
(1) SPECIFIC TERMS.—When used in this code, and when not 32 otherwise distinctly expressed or manifestly incompatible with 33 the intent thereof, the following terms shall have the following 34 meanings: 35 (n) “Internal Revenue Code” means the United States 36 Internal Revenue Code of 1986, as amended and in effect on 37 January 1, 2026 2025, except as provided in subsection (3). 38
(2) DEFINITIONAL RULES.—When used in this code and neither 39 otherwise distinctly expressed nor manifestly incompatible with 40 the intent thereof: 41 (
c) Any term used in this code has the same meaning as when 42 used in a comparable context in the Internal Revenue Code and 43 other statutes of the United States relating to federal income 44 taxes, as such code and statutes are in effect on January 1, 45 2026 2025. However, if subsection (3) is implemented, the 46 meaning of a term shall be taken at the time the term is applied 47 under this code. 48
(6) COMPUTATION OF TAXABLE INCOME.—Notwithstanding any 49 other provision of this code, amendments to the Internal Revenue 50 Code of 1986, as amended by Pub. L. No. 119-21, which affect the 51 computation of taxable income for taxable years beginning before 52 January 1, 2026, may not be given effect under this code 53 retroactively to such effective date. A limitation, a deduction, 54 an expense, or an amortization may only affect the computation 55 of taxable income for taxable years beginning on or after 56 January 1, 2026, except as provided in this chapter. The 57 amendment to the Internal Revenue Code made by s. 70301 of Pub. 58
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 3 of 10 CODING: Words stricken are deletions; words underlined are additions. L. No. 119-21 is disregarded for taxable years beginning before 59 January 1, 2027, and a taxpayer must add to and deduct from 60 taxable income those amounts deducted for federal income tax 61 purposes as bonus depreciation in a manner consistent with s. 62 220.13(1)(
e) and the Internal Revenue Code of 1986, as amended 63 by s. 13201 of Pub. L. No. 115-97. 64
Section 2. Paragraph (
e) of subsection (1) of
section 65 220.13, Florida Statutes, is amended to read: 66 220.13 “Adjusted federal income” defined.— 67
(1) The term “adjusted federal income” means an amount 68 equal to the taxpayer’s taxable income as defined in subsection 69 (2), or such taxable income of more than one taxpayer as 70 provided in s. 220.131, for the taxable year, adjusted as 71 follows: 72 (
e) Adjustments related to federal acts.—Taxpayers shall be 73 required to make the adjustments prescribed in this paragraph 74 for Florida tax purposes with respect to certain tax benefits 75 received pursuant to the Economic Stimulus Act of 2008; the 76 American Recovery and Reinvestment Act of 2009; the Small 77 Business Jobs Act of 2010; the Tax Relief, Unemployment 78 Insurance Reauthorization, and Job Creation Act of 2010; the 79 American Taxpayer Relief Act of 2012; the Tax Increase 80 Prevention Act of 2014; the Consolidated Appropriations Act, 81 2016; the Tax Cuts and Jobs Act of 2017; and the Coronavirus 82 Aid, Relief, and Economic Security Act of 2020; and the One Big 83 Beautiful Bill Act of 2025. 84 1.a.
There shall be added to such taxable income an amount 85 equal to 100 percent of any amount deducted for federal income 86 tax purposes as bonus depreciation for the taxable year pursuant 87
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 4 of 10 CODING: Words stricken are deletions; words underlined are additions. to ss. 167 and 168(
k) of the Internal Revenue Code of 1986, as 88 amended by s. 103 of Pub. L. No. 110-185; s. 1201 of Pub. L. No. 89 111-5; s. 2022 of Pub. L. No. 111-240; s. 401 of Pub. L. No. 90 111-312; s. 331 of Pub. L. No. 112-240; s. 125 of Pub. L. No. 91 113-295; s. 143 of Division Q of Pub. L. No. 114-113; and s. 92 13201 of Pub. L. No. 115-97, for property placed in service 93 after December 31, 2007, and before January 1, 2027. 94 b.
For the taxable year and for each of the 6 subsequent 95 taxable years, there shall be subtracted from such taxable 96 income an amount equal to one-seventh of the amount by which 97 taxable income was increased pursuant to this subparagraph, 98 notwithstanding any sale or other disposition of the property 99 that is the subject of the adjustments and regardless of whether 100 such property remains in service in the hands of the taxpayer. 101 c.
The provisions of sub-subparagraph b. do not apply to 102 amounts by which taxable income was increased pursuant to this 103 subparagraph for amounts deducted for federal income tax 104 purposes as bonus depreciation for qualified improvement 105 property as defined in s. 168(e)(6) of the Internal Revenue Code 106 of 1986, as amended by s. 13204 of Pub. L. No. 115-97. 107 2.
There shall be added to such taxable income an amount 108 equal to 100 percent of any amount in excess of $128,000 109 deducted for federal income tax purposes for the taxable year 110 pursuant to s. 179 of the Internal Revenue Code of 1986, as 111 amended by s. 102 of Pub. L. No. 110-185; s. 1202 of Pub. L. No. 112 111-5; s. 2021 of Pub. L. No. 111-240; s. 402 of Pub. L. No. 113 111-312; s. 315 of Pub. L. No. 112-240; and s. 127 of Pub. L. 114 No. 113-295, for taxable years beginning after December 31, 115 2007, and before January 1, 2015. For the taxable year and for 116
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 5 of 10 CODING: Words stricken are deletions; words underlined are additions. each of the 6 subsequent taxable years, there shall be 117 subtracted from such taxable income one-seventh of the amount by 118 which taxable income was increased pursuant to this 119 subparagraph, notwithstanding any sale or other disposition of 120 the property that is the subject of the adjustments and 121 regardless of whether such property remains in service in the 122 hands of the taxpayer. 123 3.
There shall be added to such taxable income an amount 124 equal to the amount of deferred income not included in such 125 taxable income pursuant to s. 108(i)(1) of the Internal Revenue 126 Code of 1986, as amended by s. 1231 of Pub. L. No. 111-5. There 127 shall be subtracted from such taxable income an amount equal to 128 the amount of deferred income included in such taxable income 129 pursuant to s. 108(i)(1) of the Internal Revenue Code of 1986, 130 as amended by s. 1231 of Pub. L. No. 111-5. 131 4.
For taxable years beginning after December 31, 2018, and 132 before January 1, 2021, there shall be added to such taxable 133 income an amount equal to the excess, if any, of: 134 a. One hundred percent of any amount deducted for federal 135 income tax purposes as business interest expense for the taxable 136 year pursuant to s. 163(
j) of the Internal Revenue Code of 1986, 137 as amended by s. 2306 of Pub. L. No. 116-136; over 138 b. One hundred percent of the amount that would be 139 deductible for federal income tax purposes as business interest 140 expense for the taxable year if calculated pursuant to s. 163(j) 141 of the Internal Revenue Code of 1986, as amended by s. 13301 of 142 Pub. L. No. 115-97. 143 144 Any expense added back pursuant to this subparagraph shall be 145
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 6 of 10 CODING: Words stricken are deletions; words underlined are additions. treated as a disallowed business expense carryforward from prior 146 years for the year or years following the addition, until such 147 time as the expense has been used. 148 5. With respect to qualified improvement property as 149 defined in s. 168(e)(6) of the Internal Revenue Code of 1986, as 150 amended by s. 13204 of Pub. L. No. 115-97, that was placed in 151 service on or after January 1, 2018: 152 a. There shall be added to such taxable income an amount 153 equal to 100 percent of any amount deducted for federal income 154 tax purposes under s. 167(
a) of the Internal Revenue Code of 155 1986. There shall be subtracted an amount equal to the amount of 156 depreciation that would have been deductible pursuant to s. 157 167(
a) of the Internal Revenue Code of 1986 in effect on January 158 1, 2020 and without regard to s. 2307 of Pub. L. No. 116-136, 159 notwithstanding any sale or other disposition of the property 160 that is the subject of the adjustments and regardless of whether 161 such property remains in service in the hands of the taxpayer. 162 b. The department may adopt rules necessary to administer 163 the provisions of this subparagraph, including rules, forms, and 164 guidelines for computing depreciation on qualified improvement 165 property, as defined in s. 168(e)(6) of the Internal Revenue 166 Code of 1986. 167 6.
For taxable years beginning after December 31, 2020, and 168 before January 1, 2026, the changes made to the Internal Revenue 169 Code by Pub. L. No. 116-260, Division EE, Title I, s. 116 and 170 Title II, s. 210 shall not apply to this chapter. Taxable income 171 under this
section shall be calculated as though changes made by 172 those sections were not made to the Internal Revenue Code. The 173 Department of Revenue may adopt rules necessary to administer 174
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 7 of 10 CODING: Words stricken are deletions; words underlined are additions. the provisions of this subparagraph, including rules, forms, and 175 guidelines for treatment of expenses and depreciation related to 176 these changes. 177 7.a. For taxable years beginning on and after January 1, 178 2027, there shall be added to taxable income an amount equal to 179 100 percent of any amount deducted for the taxable year as bonus 180 depreciation pursuant to s. 70301 of Pub. L.
No. 119-21 for 181 qualified property as defined in s. 168(k)(2) of the Internal 182 Revenue Code of 1986. 183 b. For the taxable year and for each of the 6 subsequent 184 taxable years, there shall be subtracted from such taxable 185 income an amount equal to one-seventh of the amount by which 186 taxable income was increased pursuant to this subparagraph, 187 notwithstanding any sale or other disposition of the property 188 that is the subject of the adjustments and regardless of whether 189 such property remains in service in the hands of the taxpayer. 190 c.
The department may adopt rules necessary to administer 191 this subparagraph, including rules, forms, and guidelines for 192 computing depreciation on property defined in this subparagraph. 193 8.a. For taxable years beginning on and after January 1, 194 2026, there shall be added to taxable income an amount equal to 195 100 percent of any amount deducted for the taxable year as bonus 196 depreciation pursuant to s. 70307 of Pub. L. No. 119-21 for 197 qualified production property as defined in s. 168(n)(2) of the 198 Internal Revenue Code of 1986. 199 b.
For the taxable year and for each of the 6 subsequent 200 taxable years, there shall be subtracted from such taxable 201 income an amount equal to one-seventh of the amount by which 202 taxable income was increased pursuant to this subparagraph, 203
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 8 of 10 CODING: Words stricken are deletions; words underlined are additions. notwithstanding any sale or other disposition of the property 204 that is the subject of the adjustments and regardless of whether 205 such property remains in service in the hands of the taxpayer. 206 c. The department may adopt rules necessary to administer 207 this subparagraph, including rules, forms, and guidelines for 208 computing depreciation on property defined in this subparagraph. 209 9.
For taxable years beginning on and after January 1, 210 2026, the changes made to the Internal Revenue Code to s. 174 211 and the creation of s. 174A of the Internal Revenue Code by s. 212 70302 of Pub. L. No. 119-21 do not apply to this chapter. 213 a. For taxable years beginning on and after January 1, 214 2026, there shall be added to taxable income an amount equal to 215 100 percent of any amount deducted for s. 174 or s. 174A of the 216 Internal revenue Code. 217 b.
There shall be subtracted from such taxable income an 218 amount that would have been deductible pursuant to s. 174 of the 219 Internal Revenue Code of 1986 had the amendments made to s. 174 220 and the creation of s. 174A of the Internal Revenue Code by s. 221 70302 of Pub. L. No. 119-21 not taken effect. 222 c. The department may adopt rules necessary to administer 223 this subparagraph, including rules, forms, and guidelines for 224 computing the deduction related to these changes. 225 10.a.
For taxable years beginning on and after January 1, 226 2026, there shall be added to such taxable income an amount 227 equal to 100 percent of any amount deducted for federal income 228 tax purposes pursuant to s. 179 of the Internal Revenue Code of 229 1986, as amended by s. 70306 of Pub. L. No. 119-21. 230 b. For the taxable year and for each of the 6 subsequent 231 taxable years, there shall be subtracted from such taxable 232
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 9 of 10 CODING: Words stricken are deletions; words underlined are additions. income one-seventh of the amount by which taxable income was 233 increased pursuant to this subparagraph, notwithstanding any 234 sale or other disposition of the property that is the subject of 235 the adjustments and regardless of whether such property remains 236 in service in the hands of the taxpayer. 237 c.
The department may adopt rules necessary to administer 238 this subparagraph, including rules, forms, and guidelines for 239 computing depreciation as provided in this subparagraph. 240 11.a. For taxable years beginning on and after January 1, 241 2026, there shall be added to such taxable income an amount 242 equal to 100 percent of any amount deducted for federal income 243 tax purposes pursuant to s. 274 of the Internal Revenue Code as 244 amended by s. 70305 of Pub. L. No. 119-21. 245 b.
There shall be subtracted from such taxable income an 246 amount that would have been deductible pursuant to s. 274 of the 247 Internal Revenue Code of 1986 had the amendments by Pub. L. No. 248 119-21 to s. 274 of the Internal Revenue Code not taken effect. 249 c. The department may adopt rules necessary to administer 250 this subparagraph, including rules, forms, and guidelines for 251 computing the deduction as provided in this subparagraph. 252 12.a.
For taxable years beginning on and after January 1, 253 2026, there shall be added to such taxable income an amount 254 equal to 100 percent of any amount deducted for federal income 255 tax purposes pursuant to s. 163 of the Internal Revenue Code as 256 amended by s. 70303, s. 70341, and s. 70342 of Pub. L. No. 119-257 21. 258 b. There shall be subtracted from such taxable income an 259 amount that would have been deductible pursuant to s. 163 of the 260 Internal Revenue Code of 1986 had the amendments by Pub. L. No. 261
Florida Senate - 2026 SB 7048 593-03230-26 20267048__ Page 10 of 10 CODING: Words stricken are deletions; words underlined are additions. 119-21 to s. 163 of the Internal Revenue Code not taken effect. 262 c. The department may adopt rules necessary to administer 263 this subparagraph, including rules, forms, and guidelines for 264 computing the deduction as provided in this subparagraph. 265 13.7.
Subtractions available under this paragraph may be 266 transferred to the surviving or acquiring entity following a 267 merger or acquisition and used in the same manner and with the 268 same limitations as specified by this paragraph. 269 14.8. The additions and subtractions specified in this 270 paragraph are intended to adjust taxable income for Florida tax 271 purposes, and, notwithstanding any other provision of this code, 272 such additions and subtractions shall be permitted to change a 273 taxpayer’s net operating loss for Florida tax purposes. 274
Section 3. The amendments made by this act to ss. 220.03 275 and 220.13, Florida Statutes, operate retroactively to January 276 1, 2026. 277
Section 4.
(1) The Department of Revenue is authorized, 278 and all conditions are deemed met, to adopt emergency rules 279 under s. 120.54(4), Florida Statutes, for the purpose of 280 administering this act. Notwithstanding any other law, emergency 281 rules adopted under this
section are effective for 6 months 282 after adoption and may be renewed during the pendency of 283 procedures to adopt permanent rules addressing the subject of 284 the emergency rules. 285
(2) This
section expires July 1, 2027. 286