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Staying Informed in a Rapidly Evolving Tax Policy Landscape

Success in implementing and executing a Total Tax Approach requires organizations to continually monitor the rapidly evolving legislative and regulatory landscape. With the enactment of the One Big Beautiful Bill Act or OBBBA, understanding the new provisions and their planning implications is more important than ever. Insights from a trusted advisor are essential to help you navigate and adapt to these tax changes.   

BDO provides timely, in-depth analysis of recent tax law changes and proposed tax legislation to help businesses and high net worth individuals develop strategies to effectively align with current tax policy. Our team, which includes former Congressional, IRS, Treasury, and U.S. Tax Court staff, offers guidance on recent legislation, regulations, and ongoing policy developments. 

We are committed to helping you navigate and thrive amid ongoing complexity. Explore our comprehensive tax reform resources for practical insights and let us be your primary source for staying ahead in today’s evolving landscape.

OBBBA Featured Insights

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Table of Key Tax Provisions in OBBBA

August 5, 2025

Republicans completed work on a major tax bill that would affect nearly all businesses and investors; stay informed and plan accordingly.

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Treasury, IRS Release New Guidance for Determining Beginning of Construction

August 19, 2025

Treasury and IRS issued Notice 2025-42, updating rules for when solar and wind projects begin construction. After September 1, 2025, only the physical work test applies, with exceptions for certain facilities.

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IRS Issues Procedural Guidance on OBBBA Treatment of R&E Expenditures

September 4, 2025

The IRS has issued Rev. Proc. 2025-28, outlining procedures for elections under new Section 174A from the One Big Beautiful Bill Act. The guidance highlights immediate steps for small business taxpayers regarding retroactive elections and details new options for deducting or amortizing domestic research costs.

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New York City Issues Guidance on OBBBA Decoupling Adjustments for Business Taxes

October 6, 2026

New York City has issued guidance on OBBBA decoupling adjustments for business taxes. Learn how the changes could affect Section 163(j), depreciation, R&E deductions, and filing obligations.

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Pennsylvania Issues New Section 163(j) Guidance for 2025 and Later for Corporate Income Tax Filings

September 30, 2026

Pennsylvania’s new Section 163(j) guidance may require separate-company calculations and state-specific workpapers. Learn how the changes could affect CNIT compliance.

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House Taxwriter Introduces International Reform Bill

September 24, 2026

A proposed international tax reform bill would revise FDDEI, NCTI, and BEAT rules. Explore the key provisions and what they could mean for multinational taxpayers.

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Proposed Regulations Could Affect FTC and FDDEI Calculations for Multinational Taxpayers

September 21, 2026

Treasury’s proposed international tax regulations could significantly affect foreign tax credit calculations, deduction allocation, and reporting for multinational groups with CFCs.

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Treasury Issues Proposed Regulations on CFC Pro Rata Share Rules Under the OBBBA

September 18, 2026

New CFC ownership rules may change how income and losses are allocated. See the potential effects on transactions, reporting, and tax planning.

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Proposed Section 987 Regulations Include CFC Exemption Election

September 15, 2026

The proposed Section 987 CFC election could reduce ongoing compliance requirements, but taxpayers should carefully evaluate potential impacts on gain recognition, loss treatment, and long-term tax outcomes.

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Treasury and IRS Propose Rules for Employer Contributions to Trump Accounts

September 11, 2026

Explore proposed regulations for Trump accounts and what they may mean for employers considering these benefits.

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Pennsylvania’s Changes to 163(j) Calculations Could Affect 2025 Filings

September 1, 2026

Explore the implications of Pennsylvania’s revised Section 163(j) guidance for tax years beginning in 2025 and later.

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Treasury Issues Guidance on One-Month Deferral, Foreign Tax Credit Under the OBBBA

August 27, 2026

Learn how proposed international tax regulations could affect foreign tax credits, GILTI earnings, and CFC reporting.

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California Moves to Subject Digital Prewritten Software to Sales and Use Tax

July 1, 2026

California’s new law brings sales and use tax to digital prewritten software and SaaS starting January 1, 2027, creating major implications for buyers and sellers. Read what S.B. 122 covers, where gray areas remain, and steps companies can take now.

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DOL Clarifies That Trump Accounts Generally Are Not ERISA Plans: Key Tax Considerations for Employers

June 25, 2026

New DOL guidance clarifies that Trump accounts generally aren’t ERISA-covered plans, opening the door for employers to consider a tax-favored benefit with fewer administrative demands.

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Joint Committee Offers Insight on OBBBA Interpretation

June 11, 2026

New information from Congress’s scorekeeper sheds light on how taxpayers, courts, and the IRS should interpret OBBBA provisions. Read the insight to learn more.

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Tax Legislative Roundup: Reconciliation, OBBBA Guidance Outlook, and IRS Enforcement

June 11, 2026

Congress may be gearing up for another reconciliation push as the IRS advances OBBBA guidance and enforcement efforts. Read the latest on key tax policy developments in Washington.

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IRS Issues Relief for Exempt Organization Executive Compensation Excise Tax

June 9, 2026

IRS Notice 2026-36 offers interim guidance on expanded excise tax rules for tax-exempt executive compensation. Learn what it means for ATEOs and covered employees.

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OBBBA and Medicaid: What Urban Safety Net Hospitals Need to Know Now

June 1, 2026

OBBBA and Medicaid changes could create major challenges for urban safety-net hospitals. Learn what leaders should know now to prepare and respond.

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Indiana Updates OBBBA Conformity, Offers Details on New Amnesty Program

April 30, 2026

See how Indiana’s new tax legislation and updated amnesty guidance may affect state conformity to recent federal changes and create planning considerations for 2026.

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Georgia Enacts Important SALT Bills, Several Others Await Kemp’s Signature

April 29, 2026

Georgia’s 2026 legislative session delivered notable SALT developments, including OBBBA conformity changes and proposed cuts to personal and corporate tax rates. See what’s now law and what still awaits the governor’s action.

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Healthcare Provider Taxes and the OBBBA

April 27, 2026

How the OBBBA is reshaping healthcare provider taxes: new limits, frozen rates, and a lower safe harbor threshold are changing Medicaid funding and state tax planning. See what these shifts could mean for providers and advisors.

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IRS Finalizes Rules on Occupations Eligible for OBBBA No Tax on Tips

April 15, 2026

Find out how the OBBBA tip deduction could affect workers from 2025 through 2028, including who may qualify, key limits, and IRS rules for reporting tip income.

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California’s Billionaire Tax Proposal Would Allow Sweeping, One-Time Taxation Based on Net Worth

March 30, 2026

California’s 2026 Billionaire Tax Act may reach the Nov. 3 ballot, proposing a one-time wealth tax assessed Dec. 31, 2026 and paid with 2026 returns. Learn what’s at stake—including funding goals and legal/valuation questions.

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IRS Issues Proposed Regulations on New Children’s Savings Accounts

March 18, 2026

The IRS on March 6, 2026, proposed regulations that would provide the core administrative framework for launching Trump accounts, a new type of individual retirement account (IRA) for eligible children created by the OBBBA under new Section 530A.

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Latest Interim CAMT Guidance Expands Adjustments to Financial Statement Income

February 26, 2026

Treasury and the IRS issued Notice 2026-7 with interim CAMT guidance, updating financial statement income adjustments to curb reporting‑tax mismatches that can trigger CAMT. See what changed and how it builds on recent taxpayer‑friendly CAMT notices.

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New Self-Employment Tax Ruling Alters Landscape for Limited Partners

September 24, 2026

Recent appellate court decisions provide new guidance on when partners may qualify for the limited partner exception from self-employment tax and how management activities are evaluated.

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Tax Leaders at PE-backed Portfolio Companies Pursue Growth Amid New Tax Complexity

July 7, 2026

PE-backed portfolio companies face a complex tax environment shaped by OBBBA, emerging AI adoption, and rising focus on credits and incentives. Read the insight to learn more.

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2026 BDO Tax Strategist Survey

May 19, 2026

Download the 2026 BDO Tax Strategist Survey to elevate your tax strategy with critical data and benchmark your tax function against the competition.

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Michigan Issues Detailed Guidance on Claiming Refundable R&D Credit

April 2, 2026

Michigan’s RAB 2026-4 explains how to claim the state R&D credit, with rules that differ for CIT taxpayers and flow-through entities. Learn what applies for 2025 expenses, filing deadlines, and MQRE calculation requirements.

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Fifth Circuit Overturns Tax Court on Limited Partner Self-Employment Tax Exemption

January 23, 2026

The Fifth Circuit rejected the Tax Court’s “passive investor” view of the SECA exemption for limited partners, adding momentum as similar “limited partner” cases remain pending in the First and Second Circuits.

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IEEPA Tariffs in Legal Limbo: How Importers Can Preserve Refund Rights

October 7, 2025

SCOTUS will hear arguments on Trump’s IEEPA tariffs on Nov. 5, 2025, after lower courts ruled the tariffs exceeded presidential authority. Key cases: V.O.S. Selections, CAFC, and Learning Resources v. Trump.

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California Enacts Single Sales Factor for Financial Institutions and Extends Elective PTET

July 16, 2025

California Gov. Gavin Newsom has signed S.B. 132, which requires financial institutions to use California’s mandatory single sales factor apportionment formula beginning January 1, 2025. S.B. 132 also extends the elective PTET through the 2030 tax year.

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Republicans Complete Sweeping Reconciliation Bill

July 3, 2025

The House voted 218 to 214 on July 3 to approve the Senate-passed reconciliation bill, sending the sweeping tax bill to the president’s desk for a signing ceremony that could come as early as July 4.

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Senate Proposes Major Changes to House Tax Bill

June 18, 2025

The Senate Finance Committee released a new version of the Republican tax bill, with key changes from the House version that could impact tax planning. As negotiations continue and the July 4 deadline approaches, find updates on this evolving legislation here.

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Section 232 Tariffs on Steel and Aluminum Doubled and Related Developments

June 10, 2025

Explore recent tariff changes: steel and aluminum tariffs doubled, a tariff case paused by a federal judge, and USTR extends exclusions in the China Section 301 investigation. Learn more about these impactful developments.

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