Nomadic Tax Institute

Policy updates

Publicly sourced cross-border tax developments. Dates, status and scope are shown separately so they can be read in context.

2642 updates

Scope: Global

Status requires verification

Guidance to Apply Interim Safe Harbors for Purposes of Determining a Taxpayer’s Material Assistance from a Prohibited Foreign Entity; Other Prohibited Foreign Entity Guidance

Notice 2026-15 provides interim guidance on applying PFE restrictions under the One, Big, Beautiful Bill for energy tax credits (Sections 45Y, 48E, 45X). It introduces definitions for ‘prohibited foreign entity’ (PFE), establishes a Material Assistance Cost Ratio (MACR) test to assess eligibility, and offers safe harbor provisions for facilities constructed and components sold after specific dates. These regulations impact clean electricity producers, energy storage technologies, and component manufacturers.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

2026 filing season updates and resources for seniors

IRS announced a new **enhanced deduction for taxpayers aged 65 or older** under the One, Big, Beautiful Bill: an additional $6,000 deduction per person (or $12,000 for joint filers with both spouses 65+). The deduction phases out for modified AGI over $75,000 ($150,000 joint). Other updates: changes to the Earned Income Tax Credit (EITC), resources for tax return assistance, and reminders for seniors to review withholdings and Social Security benefits reporting.

Editorial impact label: Medium

Published
Not recorded
Policy event
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Effective
Dec 31, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Change for Dyed Fuel Excise Tax Refund Claims Under OBBB

Announcement 2026-01 under the One, Big, Beautiful Bill introduces a new **statutory refund mechanism** for federal excise tax paid on dyed fuel. Taxpayers who originally paid tax on clear diesel or kerosene (first removal) and later removed it from an approved terminal as dyed fuel for a nontaxable use (on or after Dec 31, 2025) may claim a refund, subject to guidance. The IRS will issue rules for the process and eligibility. ([irs.gov](https://www.irs.gov/newsroom/treasury-irs-announce-forthcoming-guidance-on-a-new-method-for-recovering-federal-excise-tax-paid-on-dyed-fuel-established-under-the-one-big-beautiful-bill?utm_source=openai))

Editorial impact label: Low

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Guidance for Energy Tax Credits Regarding Material Assistance from Prohibited Foreign Entities

Notice 2026-15 provides **interim guidance** under the One, Big, Beautiful Bill for determining when electricity-producing qualified facilities, energy storage technologies, or eligible components receive “material assistance” from a **prohibited foreign entity (PFE)**, making them ineligible for certain energy tax credits (e.g., §§ 45Y, 48E, 45X). It lays out safe harbor cost-ratio methods, example calculations, and seeks public comments for forthcoming regulations. ([irs.gov](https://www.irs.gov/newsroom/treasury-irs-provide-guidance-for-certain-energy-tax-credits-regarding-material-assistance-provided-by-prohibited-foreign-entities-under-the-one-big-beautiful-bill?utm_source=openai))

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
Not recorded

Open cited source

Scope: United States

Proposed

Notice 2026-36: Proposed regulations for excess compensation under OBBBA

The Treasury and IRS issued Notice 2026-36 announcing proposed regulations under IRC § 4960 (excise tax on excess compensation and parachute payments) for tax-exempt organizations. Key changes include expanding the definition of “covered employee” to anyone earning over $1 million or receiving excess parachute payments, effective for taxable years beginning after December 31, 2025. Transition relief (limited hours, nonexempt funds) is provided until final regulations are issued.

Editorial impact label: High

Published
Not recorded
Policy event
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Effective
Dec 31, 2025
Verification
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Open cited source

Scope: United States

Proposed

Treasury, IRS announce intent to issue proposed regulations for excise tax on excess tax-exempt organization executive compensation under the One, Big, Beautiful Bill

Notice 2026-36 signals upcoming proposed regulations expanding excise tax liability for any employee of a tax-exempt organization earning over $1 million or receiving excess parachute payments. Applies to tax years after Dec 31, 2025; includes transitional relief and exceptions for limited hours/non-exempt funds until final regulations are released.

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

Notice 2026-23: Guidance on material assistance from Prohibited Foreign Entities for clean energy tax credits

With enactment of the One, Big, Beautiful Bill, the IRS has issued Notice 2026-15 to clarify how credits under IRC Sections 45Y, 48E (clean electricity), and 45X (advanced manufacturing production) may be denied if entities receive material assistance from prohibited foreign entities. Interim safe harbors and rules for calculating a material assistance cost ratio are provided, with full regulations to follow. This policy affects eligibility for significant energy tax credits for many companies in clean energy sectors.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
Not recorded

Open cited source

Scope: Global

Status requires verification

Treasury, IRS provide guidance on a new method for recovering federal excise tax paid on dyed fuel established under the One, Big, Beautiful Bill

Temporary regulations and a notice of proposed rulemaking permit taxpayers who paid excise tax on clear diesel or kerosene and later removed it as dyed fuel for non-taxable use (from approved terminals, mechanically dyed, etc.) to claim a refund under Form 8849. These rules are effective immediately (temporary regulations), with a statutory starting date of December 31, 2025. They will be replaced by permanent regulations when finalized.

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 provide guidance on a new method for recovering federal excise tax paid on dyed fuel established under the One, Big, Beautiful Bill

Section 6435 added by OBBB allows taxpayers who paid §4081 excise tax on diesel or kerosene—and later removed the fuel from a terminal as indelibly dyed fuel for nontaxable use—effective for removals on or after December 31, 2025—to file claims for refund using Form 8849 and Schedule 5 under the temporary regulations. These rules are in effect immediately and will remain until permanent regulations are issued, no later than three years.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
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Open cited source

Scope: United States

Status requires verification

Statutory increase in reporting and backup withholding thresholds to $2,000 under One, Big, Beautiful Bill

The OBBBA raised the reporting threshold (for payments under Forms 1099-MISC, 1099-NEC, W-2G and for backup withholding) from $600 to $2,000 for payments made after Dec 31, 2025. This reduces reporting compliance burdens for payors making payments below $2,000. Proposed regs to align regulatory language with new statute.

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

IRS CEO highlights Working Families Tax Cuts provisions: no tax on car loan interest, no tax on overtime, enhanced deduction for seniors

Under the Working Families Tax Cuts (part of the One, Big, Beautiful Bill Act), taxpayers may claim new deductions for car loan interest (on qualified U.S.-assembled personal vehicles), overtime compensation exceeding regular rate under FLSA, and enhanced standard deduction for taxpayers 65 and older—along with no tax on tips—effective for tax years 2025-2028. Hundreds of thousands of filers have already benefited; provides detailed eligibility and usage data.

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

IRS Issues Proposed Regulations on the Section 45Z Clean Fuel Production Credit (REG-121244-23)

The IRS and Treasury released proposed regulations for the Section 45Z clean fuel production credit (part of the "One, Big, Beautiful Bill" Act) setting rules for eligibility, emissions rate tables, certification and registration requirements. They clarify how non-SAF and SAF fuel must meet feedstock and foreign assistance restrictions, and establish procedures for credit applicants. Comments are due by April 6, 2026; public hearing set for May 28, 2026. ([irs.gov](https://www.irs.gov/irb/2026-09_IRB?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

New method for recovering federal excise tax paid on dyed fuel established under the One, Big, Beautiful Bill

Temporary regs & NPRM providing rules for claiming refunds of excise tax paid on clear diesel/kerosene that is later indelibly dyed and removed for nontaxable use. Limitation: claimants must be the ones who paid the tax originally. Form 8849 (and Schedule 5) to be used. Effective immediately, temporary rules expire no later than three years.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
Not recorded

Open cited source

Scope: United Kingdom

Status requires verification

International Tax Compliance (Amendment) Regulations 2025: Registration Requirement for Financial Institutions

Statutory Instrument SI 2025/740 requires reporting financial institutions and specified non-reporting financial institutions under CRS or FATCA to register with HMRC by 31 December 2025 (or by 31 January of the year after the first year in which they fall under the regime). This strengthens UK compliance with international reporting standards.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
Not recorded

Open cited source

Scope: United States

Proposed

Notice 2026-36: Expanded Application of Excise Tax on Excess Compensation under the One, Big, Beautiful Bill

Notice 2026-36 (issued June 5, 2026) announces the Treasury and IRS’s intent to issue proposed regulations expanding the definition of "covered employee" for excise tax purposes in Applicable Tax-Exempt Organizations (ATEOs). Under OBBB, this includes any employee with compensation exceeding $1 million or receiving excess parachute payments, not just the top five highest paid. Limited hours and non-exempt funds exceptions apply temporarily until further guidance. Comments on all aspects of the Notice are requested 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: United States

Proposed

Treasury, IRS issue intent to issue proposed regulations for excise tax on excess tax-exempt organization executive compensation under the One, Big, Beautiful Bill

Notice 2026-36 under the One, Big, Beautiful Bill Act expands the definition of “covered employee” for Section 4960. Under prior law, only the five highest-paid employees of a tax-exempt organization were covered; OBBBBA changes that to any employee earning over $1 million in a taxable year or receiving excess parachute payments, effective for years after December 31, 2025. Proposed regulations will also consider limited hours and non-exempt funds exceptions. Comments are solicited until 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: United States

Status requires verification

Treasury/IRS guidance on energy tax credits & prohibited foreign entity restrictions (Notice 2026-15)

Interim guidance under the One, Big, Beautiful Bill regarding the eligibility of clean electricity, energy storage and advanced manufacturing credits. The guidance defines how to calculate the material assistance cost ratio (MACR), applies safe harbor rules, and imposes restrictions if component or facility assistance is received from a prohibited foreign entity.

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

Transitional Guidance on Qualified Opportunity Zones under §§ 1400Z-1 and 1400Z-2

Notice 2026-40 provides transitional guidance for Qualified Opportunity Zones (QOZs) under §§ 1400Z-1 and 1400Z-2 as amended by the One, Big, Beautiful Bill (OBBBA), including rules for investments made before December 31, 2026 under the prior rules, treatment of QOF stock, designation periods, substantial use of property, and safe-harbors after designation period ends. Forthcoming proposed regulations will build on this guidance.

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

Temporary Regulations for Dyed Fuel Refund Method under One, Big, Beautiful Bill

As of April 30, 2026, Treasury and IRS issued temporary regulations and proposed rulemaking allowing taxpayers who paid excise tax on clear diesel or kerosene, then removed fuel as dyed for nontaxable use (on or after Dec. 31, 2025) to claim refunds using updated Form 8849 and Schedule 5, provided certain requirements are met. Regulations effective immediately and limited term. Entities must carefully document purchases, dyeing, and uses.

Editorial impact label: Medium

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
Not recorded

Open cited source

Scope: Global

Proposed

Treasury, IRS announce intent to issue proposed regulations for excise tax on excess tax-exempt organization executive compensation under the One, Big, Beautiful Bill

Notice 2026-36 announces the IRS will issue proposed regulations under IRC § 4960 expanding the definition of “covered employee” beyond the previous limitation to only the top five highest paid employees, to include any employee earning over $1 million and certain former employees. It also signals intended exceptions (limited hours, nonexempt funds), specifies that changes apply to taxable years beginning after Dec. 31, 2025, and solicits comments by **August 4, 2026**. Implications: increased liability for nonprofits, need to assess compensation structures and ensure compliance and documentation.

Editorial impact label: High

Published
Not recorded
Policy event
Not recorded
Effective
Dec 31, 2025
Verification
Not recorded

Open cited source