Scope: United States
Proposed
Notice 2026-36: Proposed regulations on excise tax on excessive compensation and excess parachute payments under OBBB
Notice 2026-36 announces the IRS’s intent to issue proposed regulations that expand the definition of “covered employee” for applicable tax-exempt organizations. Under OBBB, any employee earning over $1 million in a tax year or receiving excess parachute payments may be subject to excise taxes. The notice also provides for transition relief—allowing exceptions (e.g. limited hours and nonexempt funds) until final regulations are issued. Comments are due by August 4, 2026.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 31, 2025
- Verification
- Not recorded
Open cited source
Scope: Canada
Status requires verification
Changes to trust reporting requirements under Bill C-15 affecting bare trusts and Schedule 15 filing
From taxation years ending December 31, 2025, some bare trusts are no longer required to file Schedule 15 (Beneficial Ownership Information) with their T3 returns. Certain bare trusts will become subject to these reporting requirements starting with taxation years ending on or after December 31, 2026, depending on fair-market-value thresholds and asset types. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return/filing-trust-return/what-changed.html?utm_source=openai))
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 31, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Treasury, IRS provide guidance for certain energy tax credits regarding material assistance provided by prohibited foreign entities under the One, Big, Beautiful Bill
This guidance (Notice 2026-15) defines rules for determining whether electricity-producing facilities, energy storage technologies, eligible components are receiving material assistance from prohibited foreign entities (PFEs), and whether they are ineligible for credits under Sections 45Y, 48E, or 45X. It provides interim safe harbors, example calculations, proposes tables, and solicits public comment.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 31, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Proposed
Notice of Intent to Issue Proposed Regulations for Excise Tax on Excess Tax-Exempt Organization Executive Compensation (Section 4960)
Notice 2026-36 announces that Treasury and the IRS intend to issue proposed regulations modifying the definition of “covered employee” under section 4960 of Internal Revenue Code, extending excise tax on excess compensation & excess parachute payments for tax-exempt organizations beyond the top 5 employees to any employee earning over $1 million or under certain parachute payment rules, and soliciting comments by August 4, 2026. It also proposes exceptions such as limited hours and nonexempt funds.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 31, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Treasury, IRS: Supplemental basic allowance for housing payments to members of the military are not taxable
This policy confirms that the special one-time supplemental basic housing allowance paid to eligible uniformed service members in December 2025 is excluded from gross income and not taxable, as it is a “qualified military benefit” under the tax code.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 31, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Announcement 2026-9: Final Regulations Listing Occupations Where Workers Customarily and Regularly Receive Tips Under the One, Big, Beautiful Bill
These final regulations identify the nearly 70 occupations that qualify for the "No Tax on Tips" deduction under the OBBB Act, defining which workers may deduct up to $25,000 in qualified tips starting in tax year 2025. The list clarifies eligibility and helps taxpayers in tipped occupations understand reporting and deduction requirements.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 31, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Guidance on Qualified Long-Term Care Distributions under SECURE 2.0 (Notice 2026-33)
IRS Notice 2026-33 provides guidance on qualified long-term care distributions (QLTCD) under sections 401(a)(39) and 6050Z of the Internal Revenue Code. Distributions made after December 29, 2025 to pay for certified LTC insurance for employee or spouse may avoid the 10% early withdrawal penalty, subject to disclosure, reporting, and plan amendment safe harbor requirements.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 30, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Internal Revenue Bulletin: Notice 2026-33 — Qualified long-term care distributions under SECURE 2.0
Effective for distributions made after December 29, 2025, defined contribution plans may make *qualified long-term care distributions* to pay certified long-term care insurance for participants and spouses if conditions in §§401(a)(39) and 6050Z are satisfied. Notice clarifies disclosure and reporting duties for plan administrators and issuers of LTC insurance.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 30, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Notice 2026-3: Limited waiver of addition to tax for underpayment of estimated income tax by taxpayers making a Section 1062 election
Notice 2026-3 provides that for taxpayers making a proper Section 1062 election on qualified farmland sales, the IRS will waive portions of penalties under Sections 6654 and 6655 for underpayment of estimated tax tied to the deferred portion—excluding 75% of net tax liability from required payments; must still pay 25% by return due date.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 22, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Notice 2026-3: Estimated tax penalty relief for taxpayers making Section 1062 election in qualified farmland sales
This notice grants abatement of section 6655 penalties for estimated income tax underpayments that are solely due to making a Section 1062 election for qualified farmland sales. Taxpayers who properly make the election can compute their required estimated payments under election rules, or if penalty already assessed, seek relief by filing Form 843 with appropriate identification. Lowers compliance burden during deferral over four years.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 22, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Relief from Additions to Tax under Sections 6654 and 6655 for Underpayment of Estimated Income Tax by Taxpayers Making an Election under Section 1062 (Notice 2026-3)
Notice 2026-3 provides limited penalty relief under sections 6654 and 6655 (estimated tax underpayment penalties) for taxpayers who make a proper election under § 1062 to defer payment of tax on the sale or exchange of qualified farmland property. The IRS waives the portion of the addition to tax attributable to the deferred portion, allowing those taxpayers to avoid penalties that would conflict with the purpose of § 1062. For those who already filed returns and reported penalties, they may file Form 843 with appropriate notation to request abatement.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 22, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Final Regulations on BEAT Qualified Derivative Payments for Securities Lending Transactions
Effective December 17, 2025, corporations with substantial gross receipts engaged in payments to foreign related parties via securities lending transactions receive new guidance for determining and reporting qualified derivative payments (QDPs). The final rule enables taxpayers to use specific identification of recipients/payors to exclude mark-to-market gains or losses for BEAT purposes; if identification is not feasible, a fallback allocation method limiting inclusion is provided.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 17, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Final Regulations Under Section 892 Relating to Taxation of Income of Foreign Governments and of International Organizations
These final regulations clarify when foreign governments or their entities are treated as engaged in commercial activity or controlled commercial entities (CCE), expand the definition of financial instruments (including certain derivatives), and provide for a 180-day cure period to rectify inadvertent commercial activities. The regulations affect income derived from U.S. sources such as investments in securities. For foreign governments to maintain exemption under IRC §892, they must avoid engagement in commercial or controlling activity as per the definitions.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 15, 2025
- Verification
- Not recorded
Open cited source
Scope: United Kingdom
Status requires verification
The Customs Tariff (Establishment) (EU Exit) (Amendment) Regulations 2025
Amend the UK customs tariff from 15 December 2025: raise import duty on husked basmati rice (commodity code 1006 20 19 13 and 1006 20 99 13) from 0% to £25 per 1000 kg; restore a 14% rate for certain jam and fruit purée codes. Small-scale impact but concrete for importers/food traders.
Editorial impact label: Low
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 15, 2025
- Verification
- Not recorded
Open cited source
Scope: Global
Proposed
Treasury, IRS issue guidance providing grandfathering protection and transitional relief under Section 892 for foreign sovereign investors
Additional guidance to U.S. proposed regulation Section 892. Foreign governments and sovereign wealth funds receive grandfathering protection and transitional relief in terms of when new rules on commercial activity and effective control will apply, preserving exemption for pre-existing investments and giving time to come into compliance.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 15, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Status requires verification
Relief From Joint and Several Liability (REG-132251-11) and Community Property Law (REG-134219-08) Proposed Regulations Withdrawn
The IRS has officially withdrawn two long-standing proposed regulations—REG-132251-11 (relief from joint and several liability under IRC §6015) and REG-134219-08 (relating to relief under State community property laws) as of December 15, 2025. This withdrawal eliminates uncertainty over these proposals, but does not override existing statutory requirements. Taxpayers seeking relief under those rules must rely on current statutes and regulations until any new proposals are published. The withdrawal is effective immediately for all tax years after that date.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 15, 2025
- Verification
- Not recorded
Open cited source
Scope: Global
Status requires verification
IRS announces tax relief for taxpayers impacted by severe storms and flooding in the State of Montana; various deadlines postponed to May 1, 2026
Effective Dec 10, 2025 through May 1, 2026, tax-filing and payment deadlines are delayed for individuals and businesses in FEMA-declared disaster areas in Montana. Includes income tax returns, estimated tax payments, contributions to IRAs/HSAs, payroll and excise tax deposits, and certain returns. Penalties abated where applicable.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 10, 2025
- Verification
- Not recorded
Open cited source
Scope: United States
Proposed
Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance
Joint Treasury and IRS proposed regulations under Sections 898(c) and 960(d)(4) provide rules for allocating foreign taxes when the one-month deferral election is repealed, determining disallowed foreign tax credits for PTEP distributions under new inclusion rules, and election/tracking mechanics by U.S. shareholders of foreign corporations. Written comments due by September 17, 2026.
Editorial impact label: High
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 4, 2025
- Verification
- Not recorded
Open cited source
Scope: United Kingdom
Status requires verification
Transfer a business out of a company guidance (Disincorporation)
HMRC published fresh guidance on disincorporation, covering the tax implications when a limited company’s business and assets are transferred to its shareholders who then operate as sole traders or partners. It outlines impact on Corporation Tax, VAT, Capital Gains, Income Tax, and provides examples for different closure options (members’ voluntary liquidation vs striking off).
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 1, 2025
- Verification
- Not recorded
Open cited source
Scope: Australia
Proposed
Introduction of the Budget Repair Levy
The government has proposed a new temporary levy on high-income earners to address budget deficits, aiming to raise additional revenue by 2% on incomes over $180,000.
Editorial impact label: Medium
- Published
- Not recorded
- Policy event
- Not recorded
- Effective
- Dec 1, 2025
- Verification
- Not recorded
Open cited source