Monthly US Tax Bulletin - January 2026

Key highlights:

Federal taxes

• The IRS has proposed transition rules as per Notice 2025-75 under the One, Big, Beautiful Bill Act (OBBBA) clarifying that certain mid‑2025 dividends that do not increase the U.S. taxable income will not reduce Subpart F or GILTI inclusions when Controlled Foreign Corporation (CFC) stock is acquired mid‑year, for CFC tax years beginning from 28 June 2025 to 1 January 2026.
• Effective from 21 November 2025, the IRS has finalised regulations for the 1% Stock Repurchase Excise Tax under IRC §4501.
• The Treasury and the IRS, under Notice 2025-77, have proposed rules to limit foreign tax credits on the distributions of previously taxed earnings and profits (PTEP) under §960(d)(4).
• The IRS proposes under Notice 2025-78 clarifications on exclusions from deduction-eligible income under IRC §250, defines the scope for intangible and depreciable property, and outlines changes that may reduce Section 250 deductions effective 16 June 2025.
• The US Citizenship and Immigration Services (USCIS) has launched the Gold Card Programme with Form I-140G for employment-based immigrant visas requiring significant donations and online registration.

State taxes

• Tennessee reaffirms adherence to the TCJA bonus depreciation phase-out schedule for excise tax purposes, rejecting the OBBBA’s 100% bonus depreciation and requiring adjustments on Schedule J. 
• Minnesota announces non-conformity with federal tax changes after 1 May 2023, including the OBBBA provisions, requiring businesses to use Schedule M4NC to report adjustments for bonus depreciation, research and experimental expenses, interest limitations, and other deductions when filing the 2025 returns. 
• New Jersey updates research and development tax credit rules under Technical Bulletin (TB) 114, allowing same-year deductions and offering a 10% non-refundable credit on qualified research expenses with compliance requirements pertaining to the submission of Form 306. 
• Louisiana issued a guidance on sales tax treatment of transportation charges, specifying when delivery fees are taxable or exempt.

Monthly US Tax Bulletin - January 2026

The January 2026 edition of the Grant Thornton Bharat Monthly US Tax Bulletin provides a concise summary of recent key developments in federal and state taxes in the US.

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