Tax planning for 2026 is coming into focus as guidance and litigation begin to fall into place.
Bloomberg’s 2026 Tax Policy Outlook outlines how recent tax changes are moving into an implementation phase, with full expensing provisions reinstated, adjustments underway to the corporate minimum tax and key elements of the global minimum tax framework already revised.
At the same time, provisions tied to capital investment, corporate minimum taxes and international coordination continue to take shape as the IRS issues guidance and courts address unresolved disputes.
Here are seven CFO-centric takeaways from the report:
1. Bonus depreciation and targeted expensing are reinstated
The tax law permanently reinstates bonus depreciation, allowing upfront deductions for certain capital assets rather than spreading those deductions over time. It also provides 100% bonus depreciation for qualified manufacturing facilities placed in service before Jan. 1, 2031, expanding incentives tied to domestic production.
The report notes that additional IRS guidance is still needed to clarify which properties qualify under these provisions, with practitioners citing uncertainty around eligibility and scope.
2. The corporate alternative minimum tax is being narrowed through guidance
Treasury has taken steps to reduce the reach of the 15% corporate alternative minimum tax, including exemptions for insurance, shipping and utility companies and the exclusion of unrealized cryptocurrency gains. These changes follow criticism that earlier proposed rules were overly complex.
Further guidance is expected, particularly for companies with large research and development spending. The report characterizes the changes as adjustments to how the tax applies, rather than a repeal of the minimum tax itself.
3. IRS staffing and leadership challenges continue
The report states that the IRS workforce declined by about 25%, to roughly 75,000 employees, following early retirement and resignation offers in 2025. The agency continues to face turnover, funding uncertainty beyond January, a legal battle with President Donald Trump and the possibility of another government shutdown early in the filing season.
These conditions are cited as factors that could influence enforcement capacity, the pace of guidance issuance and the speed at which cases are resolved in 2026.
4. Large transfer pricing disputes remain unresolved
Several multibillion-dollar transfer pricing cases, including disputes involving 3M, Meta, Airbnb and Coca-Cola, are identified as among the most significant litigation matters continuing into 2026. The report highlights these cases by dollar magnitude.
Recent court decisions have focused closely on valuation methodologies and the assumptions underlying intercompany pricing, shaping how similar disputes are evaluated even as outcomes remain pending.
5. U.S. companies are exempt from key elements of the global minimum tax
International negotiators agreed to exempt U.S. companies from core provisions of the Organisation for Economic Co-operation and Development’s global minimum tax, establishing a side-by-side system that allows U.S. tax rules to operate alongside the international framework. The agreement includes safe harbors tied to eligible tax regimes.
The report also notes that transitional country-by-country reporting relief has been extended through 2027, alongside the introduction of an effective tax rate safe harbor intended to simplify compliance.
6. Expanded qualified small business stock rules influence transaction structuring
The tax law expanded the qualified small business stock gain exclusion, a provision commonly used in venture-backed investments. The report describes the expansion as having immediate implications for how companies assess eligibility.
Tax professionals cited in the report say the change is already influencing how transactions are structured, particularly in the mergers and acquisitions space.
7. Deductions for overtime and tipped income move toward implementation
Deductions for some overtime and tipped income take effect in tax year 2025, increasing the urgency of guidance ahead of the 2026 filing season. The Treasury has issued transition guidance for overtime and proposed rules for tipped income.
The report notes that practitioners continue to seek clarity on what qualifies as overtime and tips under the new provisions, signaling that further interpretation will be required.
