Monthly US Tax Bulletin - April 2026

Key highlights:

Federal taxes

• The OECD's outline of a phased peer-review framework is intended to assess countries’ implementation of Pillar Two rules, focusing on consistency with the GloBE Model Rules, technical alignment, and administrative effectiveness. It aims to promote convergence and determine the qualification of domestic taxes for multinational groups without penalising early adopters.
• Liechtenstein has launched a consultation to update its Pillar Two Safe Harbor Rules in line with the OECD GloBE standards, with revised provisions proposed to take effect from 1 January 2027.
• A new U.S. House Bill (H.R. 8101) introduced on 26 March 2026 proposes reversing recent §163(j) changes by restoring the inclusion of certain foreign income in business interest limitation calculations. However, its chances of becoming law remain uncertain.
• With the 2026 FIFA World Cup approaching, non-resident individuals and foreign entities participating in U.S.-hosted events should carefully evaluate potential U.S. tax, withholding, and reporting obligations, including available treaty relief under the IRS guidance.
• The IRS released its 2026 “Dirty Dozen” list, cautioning taxpayers about sophisticated and emerging tax scams, including AI-based impersonation and improper claims, to help prevent fraud, penalties, and financial loss.
• The IRS issued Revenue Procedure 2026‑15, updating the inflation-adjusted depreciation limits and lease-inclusion amounts for business passenger vehicles placed in service or leased in 2026.

State taxes

• California has proposed sweeping changes to its water’s‑edge reporting regime under AB 1790, potentially tightening controlled foreign corporation (CFC) income inclusion and transitioning to worldwide combined reporting. However, the bill remains under consideration and has not yet been enacted.
• Washington has introduced a temporary ESSB 5814 Penalty Relief Programme, offering eligible businesses a penalty waiver to ease compliance with the newly expanded retail sales tax rules, effective from 1 October 2025. 
• New York has enacted legislation to modernise electronic signature procedures for tax filings, aligning state practices with IRS standards and authorising digital signatures from 1 July 2027.
• Alabama has enacted legislation amending its unclaimed property law to include digital assets, such as cryptocurrencies, and to update reporting, custody, and consumer protection rules.
• New Mexico has enacted SB 151, implementing corporate tax reforms effective from 2027, including decoupling from federal bonus depreciation, shifting to an Earnings Before Interest and Taxes (EBIT)- based interest limitation, and including net CFC-tested income in the state tax base.

Monthly US Tax Bulletin - April 2026

The April 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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