Details of Public Law 119-21, section 70428 , One Big Beautiful Bill Act

This provision provides that certain activities substantially related to the participation or investment in fisheries in the Bering Sea and Aleutian Islands regions carried out by eligible Alaskan villages listed under the Magnuson-Stevens Fishery Conservation and Management Act, are considered qualifying activities for constituting the basis of such entity’s federal income tax exemption status under IRC section 501(a).

In addition, a wholly owned subsidiary that transfers its assets from a trade or business related to the participation or investment in fisheries in the Bering Sea and Aleutian Islands regions to an eligible entity listed under the Magnuson-Stevens Fishery Conservation and Management Act, no later than 18 months after July 4, 2025, will not recognize gain or income from the transfer of the assets and all income from the transfer is exempt from taxation.

California, under the PITL and CTL, does not conform to IRC section 501 but instead has standalone law that is generally similar to federal law. As a result, California does not conform to the changes made under this provision.