Key takeaways:

• • • Your post-OBBBA forecasts should look different 鈥� If the tax department doesn’t own the OBBBA model, someone else will own the OBBBA story.

• • • Rely on your department鈥檚 inner strengths 鈥� It鈥檚 governance and analysis 鈥� not tools 鈥� that get you into the strategy room.

    • Factor in the conflict in the Middle East 鈥� The Iran war risk belongs in your tax model, not just in your CFO’s macro deck.

The One Big Beautiful Bill Act (OBBBA), signed into law in July 2025, enacted large business tax cuts, most notably by providing permanent full expensing of many forms of investment. Under the previous major corporate tax legislation, 2017鈥檚 Tax Cuts and Jobs Act (TCJA), bonus depreciation was scheduled for gradual phase-out following 2023. The OBBBA restored that expensing 100% retroactively for assets acquired from mid-January 2025 onwards.

The after-tax cost of new machinery, fleets, and equipment has effectively fallen by around 21%, designed to encourage immediate capital outlays by allowing businesses to write off these expenses in the year they are incurred rather than amortizing them over five years.

For corporate tax departments, that’s not a disclosure footnote 鈥� that’s your capital plan.

Capital-intensive corporations will see tax burdens reduced through permanent rate extensions, depreciation adjustments, and expansion of the state and local tax (SALT) deduction cap 鈥� but only if your models are built to capture the timing and location of investment, the mix of debt compared to equity, and where your organization books its next dollar of income.

Not surprisingly, most corporate tax departments aren’t there yet. They’re still recalculating last year, plus a few adjustments. That’s glorified compliance, not modeling.

A standout tax department doesn’t ask, What’s the OBBBA impact? Rather, it asks, Which version of OBBBA do we choose for this business? 鈥� and it has the models to back it up.

From spreadsheet heroics to controlled modeling

For many organizations, tax modeling still means creating a massive spreadsheet that only one director truly understands. The spreadsheet gets pulled out for budget season, rebuilt under pressure, and quietly retired until next year. That’s a single point of failure, not a process.

And after OBBBA, continuing that practice is dangerous. One wrong assumption on expensing or interest limitation can move cash tax by millions of dollars and blindside the Finance Department.

Here’s what disciplined modeling looks like in practice:

• • • Create a unified model 鈥� Build one integrated model that the whole team can use or accept that your department is choosing to fly blind.
    • Use the same assumptions 鈥� Standardize the levers that matter most (such as capex timing, financing mix, jurisdiction, and incentives) and make sure every scenario runs off the same assumptions.
    • Conduct modeling reviews 鈥� Treat major OBBBA-driven decisions (such as large capex, funding shifts, supply-chain redesign) as tax deals that must go through a modeling review before they’re greenlit.
    • Document your assumptions explicitly 鈥� Under permanent full expensing, the difference between a well-supported assumption and a poorly documented one isn’t just an audit risk, rather it’s a credibility problem with your CFO.

It鈥檚 also important to remember that in a post-OBBBA world, this level of disciplined modeling is not technology transformation 鈥� it鈥檚 basic survival.

Governance: Where leaders quietly win or loudly fail

The differentiator isn’t which corporate tax department has the fanciest tool 鈥� it’s which one has the cleanest governance. And the data is unambiguous: More than half (55%) of tax departments are still in the reactive phase of their technological development, stuck with five capex models circulating with five discount rates and the tax team arriving late to the planning meeting.

Those tax departments that are breaking out of that pattern share one trait: They put someone formally in charge. In the 成人VR视频 Institute鈥檚 recent 2026 Corporate Tax Department Technology Report, a large portion (88%) of survey respondents said their company had appointed a person to lead the tax department’s technology strategy. That number jumped a whopping 37 percentage points, from 51%, from the previous year鈥檚 survey. That single structural move separates those departments with a governance model from those that simply hold a governance conversation every budget cycle and forget about it.

Clearly, this type of ownership drives results. Two-thirds of those surveyed agreed that their company’s investment in technology has enabled a shift from routine, reactive work to more strategic, proactive, higher-value work.

Under OBBBA, the kind of governance isn’t housekeeping. It’s how you get invited into strategy discussions instead of having to clean up after things go awry.

Why your OBBBA win may not feel like a win

On paper, the tax changes embedded in the OBBBA look generous. In practice, your effective tax benefit is colliding with something you don’t control.

When the war on Iran began, all shipping through the Strait of Hormuz was effectively halted, removing roughly one-fifth of the world’s oil and gas supply from the market. Fuel prices throughout the world spiked and are likely to remain elevated as long as conflict persists.

With oil prices hovering around $100 a barrel, there are will wipe out the benefits of higher tax refunds this year for most Americans. If those benefits, arising from Trump’s 2025 tax cuts, are erased for the average American, only the top 30% of taxpayers will still seeing a net gain.

For corporate planning purposes, the parallel dynamic is real: The topline OBBBA benefit is being eroded by higher fuel, freight, and financing costs across the business and its supply chain.

Inflationary pressures are being driven by higher energy prices tied to the Iran war, and the conflict’s impact on a wide range of goods and services is likely to last for months 鈥� with experts saying even a ceasefire is unlikely to immediately ease global energy shortages.

A serious corporate tax department doesn’t handwave these concerns away. It takes three actions:

1. 1. 1. Run a war-extended scenario 鈥� The scenario should show exactly how sustained higher energy costs and borrowing rates change the payoff from accelerated expensing and leverage 鈥� with specific numbers, not just directional commentary.
      2. Share your forecasts internally 鈥� Put your monthly or quarterly cash-tax forecasts on the table for Finance to see, so that it can manage liquidity rather than hope the annual plan holds.
      3. Force the hard conversation 鈥� Ask the tough question: At today’s rates and fuel costs, the after-tax return on this project is X. Are we still in? That question should come from the tax team now, not from the finance team six months later.

Clearly, the daily fluctuations in oil prices matter less than monthly and quarterly averages 鈥� and volatility will likely remain elevated given the absence of a clear timeline for the end of the war. That’s exactly the kind of sustained uncertainty that belongs front and center in your scenario set, not in a footnote.

The bottom line

The OBBBA gives corporate tax departments a genuine opportunity to move from being simply a compliance function to becoming more of a strategic advisor. Permanent full expensing, richer cost recovery, and more flexible interest rules can create real levers to add value, but only for those organizations that model them rigorously, govern them cleanly, and stress-test them against the macro environment their business actually faces today.

Indeed, the Iran war is a live test of that readiness. The corporate tax departments that show up with modeled scenarios, cash-tax forecasts, and a clear point of view on after-tax returns will earn a seat at the strategy table. The ones that show up with caveats will be asked to leave it.

You can download a full copy of the 成人VR视频 Institute鈥檚 recent 2026 Corporate Tax Department Technology Report here

Key takeaways:

• • • Country-by-country reporting will only increase in complexity 鈥� Australia’s enhanced Country-by-country reporting (CbCR) requirements 鈥� reconciling taxes accrued against taxes credited 鈥� are a preview of where other high-scrutiny jurisdictions are heading, and companies need to build that explanatory analysis capability now, systematically, rather than scrambling later.

    • There has to be a shared narrative from corporate teams 鈥� The EU鈥檚 public CbCR is a reputational event, not just a filing. So that means tax, communications, and investor relations teams need a shared narrative before the data goes public 鈥� inconsistencies create exposure you do not want to manage reactively.

    • Rethink your filing jurisdiction in light of changes 鈥� If EU filing jurisdiction was chosen at initial implementation and never revisited, look again. Guidance has matured, and a more efficient or better-suited option may now be available.

WASHINGTON, DC 鈥� Among the many pressing topics discussed in detail at the recent , country-by-country reporting (CbCR) and its ability to reshape the corporate tax industry, certainly had its place. Between escalating local jurisdiction requirements, the , and for deeper explanatory disclosures, CbCR has quietly evolved from a transfer pricing filing obligation into something far more strategically consequential.

The floor is just the floor

The creation of the by the Organisation for Economic Co-operation and Development (OECD) was intended as a minimum standard for countries. And now jurisdictions are increasingly layering additional requirements on top of the OECD鈥檚 basic template, resulting in a widening gap between the standard requirements and what tax authorities actually want.

Currently, Australia is the most pointed example. Australian tax authorities are now requiring multinational groups to go beyond the standard CbCR data fields and provide explanatory narratives that reconcile taxes accrued against taxes actually credited. This requires corporate tax departments to bridge the gap between financial statement accruals and their organizations鈥� cash tax positions in a way that is coherent, defensible, and consistent with positions taken elsewhere.

At the TEI event, panelists explained that for tax departments this will carry complex timing differences, deferred tax positions, or significant jurisdictional mismatches between booked and cash taxes. Indeed, this additional layer of scrutiny will need dedicated attention.

The broader signal matters: Australia will not be the last jurisdiction to move in this direction. So that means that tax departments should treat Australia’s approach as a leading indicator of where other high-scrutiny jurisdictions could be heading. Building the capability to produce this kind of explanatory analysis systematically 鈥� rather than scrambling jurisdiction by jurisdiction 鈥� would be the smarter long-term investment for corporate tax teams.

Public CbCR in the EU: The transparency ratchet has turned

For US-based multinationals with significant European operations, the EU’s public CbCR directive has fundamentally changed the calculus. Unlike the confidential tax authority filings most corporate tax departments are accustomed to, the EU鈥檚 public CbCR rules put organizations鈥� jurisdictional profit and tax data into the public domain, making it visible to investors, journalists, civil society groups, and organizations鈥� employees and customers.

The EU framework specifies which entities trigger the reporting obligation and which entity within the group is responsible for making the public filing. That scoping analysis is not always straightforward for complex multinational structures and getting it wrong could present both reputational and legal risk.

Choosing a filing jurisdiction is not purely an administrative decision 鈥� it is a choice that affects the regulatory environment that governs the disclosure, the language requirements, the timing, and the interpretive framework that applies to data.

For US-headquartered groups, the implications extend well beyond Europe. Public CbCR data is now being read alongside US disclosures, reporting on ESG activities, and public narratives about tax governance. Inconsistencies, including those technically explainable, could create unwanted noise about the company. This is clearly another reason why the tax function should partner across the business 鈥� in this case with the communications team 鈥� to make they both are aligned to tell the CbCR story instead of being caught off guard by a journalist or an investor during an earnings call.

Questions that US multinationals should be asking

Fortunately, US multinationals with multiple EU subsidiaries are not required to file public CbCR reports in every EU member state in which they have a presence. Instead, under the EU framework, a qualifying ultimate parent or standalone undertaking can satisfy the public disclosure requirement through a single filing in one EU member state, provided the relevant conditions are met. Germany and the Netherlands have emerged as two of the more popular choices for this consolidated filing approach, given their well-developed regulatory frameworks and the depth of available guidance on what compliant disclosure looks like in practice.

The strategic implication is meaningful. Choosing a filing jurisdiction is not purely an administrative decision 鈥� it is a choice that affects the regulatory environment that governs the disclosure, the language requirements, the timing, and the interpretive framework that applies to data. Corporate tax departments that defaulted to a filing jurisdiction early in the EU implementation process should take a fresh look. Regulatory guidance has matured significantly, and there may be a more efficient or better-suited path available than the one originally chosen.

The uncomfortable divergence

There is a notable irony in the current environment. Domestically, the IRS and U.S. Treasury’s 2025-2026 Priority Guidance Plan reflects an explicit focus on deregulation and burden reduction, detailing dozens of projects aimed at reducing compliance costs for US businesses. Meanwhile, the international compliance environment has moved in the opposite direction, adding disclosure layers, explanatory requirements, and public transparency obligations that many US businesses cannot avoid simply because they are headquartered in the United States.

This divergence has a direct implication for how tax departments allocate resources and make the internal case for investment in international compliance infrastructure. The burden internationally is not going down 鈥� indeed, it is intensifying 鈥� and that argument is now backed by concrete examples rather than projections.

3 things worth doing now

There are several actions that corporate tax teams should consider, including:

Audit CbCR data quality with Australia’s enhanced requirements in mind 鈥� If you cannot readily reconcile taxes accrued to taxes credited at the jurisdictional level, that gap needs to be closed before it becomes an authority inquiry.

Revisit EU filing jurisdiction strategy 鈥� If your jurisdictional decision was made at the time of initial implementation and has not been reviewed since, it is worth a fresh look before the next reporting cycle.

Develop an internal narrative around public CbCR data before it circulates externally 鈥� Your company鈥檚 tax story should not be a surprise to the corporate teams involved in communications, investor relations, or ESG 鈥� and in today鈥檚 world, assuming such news stays quiet is no longer a safe assumption.

While CbCR started as a tool for tax authorities, it today has become something more visible, more public, and more consequential than that 鈥� and that trajectory is not reversing any time soon.

You can download a full copy of the 成人VR视频 Institute鈥檚

Key takeaways:

• • • Only IEEPA鈥慴ased tariffs are up for refund 鈥� Refunds will flow electronically to importers of record through ACE, the government鈥檚 digital import/export system, but only once CBP鈥檚 process is finalized.

    • Liquidation and protest timelines are now critical 鈥� An organization鈥檚 tax concepts that directly influence which entries are eligible and how long companies have to protect claims.

    • Tax functions must quickly coordinate with other corporate functions 鈥� In-house tax teams need to coordinate with their organization鈥檚 trade, procurement, and accounting functions to gather data, assert entitlement, and get the financial reporting right on any tariff refunds.

WASHINGTON, DC 鈥� When the United States Supreme Court issued its much-anticipated ruling on President Donald J. Trump鈥檚 authority to impose mass tariffs under the International Emergency Economic Powers Act (IEEPA) in February it set the stage for what it to come.

The Court ruled the president did not have authority under IEEPA to impose the tariffs that generated an estimated $163 billion of revenue in 2025. In response, the Court of International Trade (CIT) issued a ruling in requiring the U.S. Customs and Border Protection (CBP) to issue refunds on IEEPA duties for entries that have not gone final. That order, however, is currently suspended while CBP designs the refund process and the government considers an appeal.

At听the recent , tax experts discussed what this ruling means for corporate tax departments, outline what is and isn鈥檛 a consideration for refunds and the steps necessary to apply for refunds.

As panelists explained, the key issue for tax departments is that only IEEPA tariffs are in scope for refund 鈥� many other tariffs remain firmly in place. For example, on steel, aluminum, and copper; Section 301 tariffs on certain Chinese-origin goods; and new of 10% to 15% on most imports still apply and will continue to shape effective duty rates and supply chain costs.

So, which entities can actually get their money back?

Legally, CBP will send refunds only to the importer of record, and only electronically through the government鈥檚 digital import/export system, known as the Automated Commercial Environment (ACE) system. That means every potential claimant needs an with current bank information on file. And creating an account or updating it can be a lengthy process, especially inside a large organization.

If a business was not the importer of record but had tariffs contractually passed through to it 鈥� for example, by explicit tariff clauses, amended purchase orders, or separate line items on invoices 鈥� they may still have a commercial basis to recover their share from the importer. In practice, that means corporate tax teams should sit down with both the organization鈥檚 procurement experts and its largest suppliers to identify tariff鈥憇haring arrangements and understand what actions those importers are planning to take.

Why liquidation suddenly matters to tax leaders

As said, the Atmus ruling is limited to entries that are not final, which hinges on the . CBP typically has one year to review an entry and liquidate it (often around 314 days for formal entries) with some informal entries liquidating much sooner.

Once an entry liquidates, the 180鈥慸ay protest clock starts. Within that window, the importer of record can challenge CBP鈥檚 decision, and those protested entries may remain in play for IEEPA refunds. There is also a 90鈥慸ay window in which CBP can reliquidate on its own initiative, raising questions about whether final should be read as 90 days or 180 days 鈥� clearly, an issue that will matter a lot if your company is near those deadlines.

Data, controversy risk & financial reporting

The role of in-house tax departments in the process of getting refunds requires, for starters, giving departments access to entry鈥憀evel data showing which imports bore IEEPA tariffs between February 1, 2025, and February 28, 2026. If a business does not already have robust trade reporting, the first step is to confirm whether the business has made payments to CBP; and, if so, to work with the company鈥檚 supply chain or trade compliance teams to access ACE and run detailed entry reports for that period.

Summary entries and heavily aggregated data will be a challenge because CBP has indicated that refund claims will require a declaration in the ACE system that lists specific entries and associated IEEPA duties. Expect controversy pressure: As claims scale up, CBP resources and the courts could see backlogs. If that becomes the case, tax teams should be prepared for protests, documentation requests, and potential litigation over entitlement and timing.

On the financial reporting side, whether and when to recognize a refund depends on the strength of the legal claim and the status of the proceedings. If tariffs were listed as expenses as they were incurred, successful refunds may give rise to income recognition. In cases in which tariffs were capitalized into fixed assets, however, the accounting analysis becomes more nuanced and may implicate asset basis, depreciation, and potentially transfer pricing positions.

Coordination between an organization鈥檚 financial reporting, tax accounting, and transfer pricing specialists is critical in order that customs values, income tax treatment, and any refund鈥憆elated credits remain consistent.

Action items for corporate tax departments

Corporate tax teams do not need to become customs experts overnight, but they do need to lead a coordinated response. Practically, that means they should:

• • • confirm whether their company was an importer of record and, if so, ensure ACE access and banking information are in place now, not after CBP turns the refund system on.
    • map which entries included IEEPA tariffs, identify which are non鈥憀iquidated or still within the 180鈥慸ay protest window, and file protests where appropriate to protect the company鈥檚 rights.
    • inventory all tariff鈥憇haring arrangements with suppliers, assess contractual entitlement to pass鈥憈hrough refunds, and align with procurement and legal teams on a consistent recovery approach.
    • work with accounting to determine the financial statement treatment of potential refunds, including whether and when to recognize contingent assets or income and any knock鈥憃n effects for transfer pricing and valuation.

If tax departments wait for complete certainty from the courts before acting, many entries may go final and fall out of scope. The opportunity for tariff refunds will favor companies that are data鈥憆eady, cross鈥慺unctionally aligned, and willing to move under time pressure.

You can find out more about the changing tariff situation here

• • • Changing the balance of taxes 鈥� Budget鈥慸riven tax swaps and incentive reforms are changing the balance between income, property, and sales taxes, forcing large companies to revisit their multistate footprint.

    • How revenue is sourced is changing, too 鈥� Rapidly evolving digital and AI鈥憆elated taxes are creating new nexus, sourcing, and base鈥慸efinition issues for businesses that rely on revenue from digital advertising, social platforms, data monetization, and automated tools.

    • Planning amid continued uncertainty 鈥� New federal tax regulations, tariff鈥憆elated uncertainty, and even the elimination of the penny are all amplifying state鈥慴y鈥憇tate complexity for in鈥慼ouse tax departments.

WASHINGTON, DC 鈥� Tax industry experts who gathered at to provide updates on the current landscape of state and local tax (SALT) policy and offer insight that corporate tax departments should consider found, not surprisingly, that they had a lot to talk about in the current economic environment.

Mapping the new SALT frontier

For starters, this year鈥檚 SALT agenda is not just an abstract policy story for large, multistate businesses, rather, it鈥檚 a direct driver of cash taxes, effective tax rate (ETR) volatility, and audit exposure. Indeed, several state legislatures are advancing new taxes on digital advertising and data, revisiting incentives and data center exemptions, and using conformity to federal law 鈥� especially the tax provisions in the One Big Beautiful Bill Act (OBBBA) 鈥� as a policy lever, all against the backdrop of slowing revenues and contentious elections.

鈥淭ax swaps鈥� and incentives 鈥� States that are facing budget pressure are, unsurprisingly, looking at tax swaps to reduce income or property taxes while broadening the sales & use tax base and trimming exemptions. For example, on March 3, the state of Florida 鈥� which already doesn鈥檛 have a state income tax 鈥� passed legislation that in the state.

Moreover, with the rapid expansion of AI come the extensive need for data centers. Several states are reassessing data center exemptions and credits, either tightening qualification standards, requiring centers to supply more of their own power, or repealing incentives outright. A decision in Virginia to , for example, is viewed as a potential template for other states, particularly in those areas in which energy and environmental concerns are priorities. At the same time, proposals targeting include expanded corporate tax disclosures, CEO compensation surcharges, and enhanced reporting on apportionment and group filing methods.

What companies should consider 鈥� Large companies operating over multiple states should consider making an inventory of their credits and incentives by jurisdiction, including looking at sunset dates and political risk indicators.

Companies should also build forward鈥憀ooking models that show how any sales tax base expansion would interact with their supply chain and their procurement of digital and professional services.

New exposure for tech, marketing & data

Bipartisan legislators in several states are continuing to expand on digital economies as a revenue and policy target. For example, Maryland continues to lead with its digital advertising tax; while Washington state鈥檚 expansion of its sales tax to include certain digital and IT services and Chicago鈥檚 social media taxes illustrate the variety of approaches that state and local jurisdictions are exploring to expand their tax base and raise revenue.

Data and 鈥渄igital resource鈥� taxes 鈥� Proposals in states such as New York would tax companies that derive income from resident data, treating data as a natural resource. While no state has fully implemented a comprehensive data tax, however, large platforms and data鈥慸riven enterprises are monitoring these bills closely.

AI鈥憆elated SALT rules 鈥� Many states still classify AI solutions under existing Software as a Service (SaaS) or data鈥憄rocessing categories, but some 鈥� including New York 鈥� are exploring surcharges tied to AI鈥慸riven workforce reductions. And at least two states are explicitly taxing AI, similarly to the way software is taxed.

For corporate tax leaders, some practical next steps should include mapping those areas in which your group has digital ad spending, user bases, data monetization, or AI deployments. Then, overlaying that with current and pending digital tax proposals. In parallel, it is increasingly critical for the tax team to partner with IT and marketing teams to understand how contracts, invoicing structures, and platform design will affect nexus, tax base definition, and sourcing.

Federal shifts magnify multistate complexity

The OBBBA made permanent several of , while expanding SALT relief on the individual side and creating new interactions for multinational groups. Because most states start from federal taxable income 鈥� either on a rolling, static, or selective conformity basis 鈥� OBBBA changes reverberate across state corporate income tax bases, especially in those states that have decoupled themselves from interest limits, R&D expensing, or new production鈥憆elated incentives.

Corporate tax departments must now juggle different conformity dates and selective decoupling rules across rolling and static states, including jurisdictions that automatically decouple when a federal change exceeds a revenue impact threshold. This requires more granular state鈥慴y鈥憇tate modeling of OBBBA impacts on apportionable income, deferred tax balances, and cash tax forecasts. It also heightens the risk that political disputes 鈥� such as 鈥� produce mid鈥慶ycle changes that complicate provision and compliance processes.

Penny elimination 鈥� With federal , states now are moving toward symmetrical rounding for cash transactions, rounding the final tax鈥慽nclusive total to the nearest five cents while attempting not to alter the underlying tax computation. For retailers and consumer鈥慺acing enterprises, this shifts the focus to point of sale (POS) configuration, consumer鈥憄rotection exposure, and class鈥慳ction risk if rounding is implemented incorrectly.

Tariffs and refunds 鈥� The U.S. Supreme Court鈥檚 Learning Resources, Inc. v. Trump decision under the International Emergency Economic Powers Act in February leaves open how more than $100 billion in and what that means for prior sales & use tax treatment. Streamlined guidance generally treats tariffs embedded in product prices as part of the taxable sales price but excludes tariffs paid directly by a consumer鈥慽mporter from the tax base, raising complex questions if tariff refunds reduce costs or sales prices retroactively.

For indirect tax department teams, the confluency of the 2026 SALT changes 鈥� including the impacts around everything from data center credits to the recent Supreme Court tariff decision 鈥� the need to rely on internal partners across the business has never been stronger. Combining that with a greater reliance on technologies, including dedicated research tools to stay abreast of state-by-state tax changes, may be the best way for corporate tax teams to keep up with compliance requirements and avoid penalties.

You can download a full copy of here

Key takeaways:

• • • The supply hit is real, not just priced-in fear 鈥� Tanker insurance has collapsed, infrastructure is damaged, and volumes are physically offline. Some of this isn’t coming back quickly.

    • Tax policy is moving in five directions at once 鈥� Energy security incentives, BEPS 2.0 rollout, windfall tax rumblings 鈥� governments are improvising, and your effective tax rate is caught in the middle.

    • Your Evidence to Recommendations (EtR) guidance is probably already stale 鈥� If you haven’t stress-tested your EtR guidance against $100-plus per barrel oil and a multi-quarter disruption, you’re behind.

Let’s be direct: This isn’t a risky premium situation. When military strikes take out Middle Eastern infrastructure in the Persian Gulf and tanker insurers pull out of a corridor carrying 15% to 20% of global crude and liquefied natural gas (LNG), supply goes offline. That’s what’s happened.

At the time of writing, the price of oil continues to fluctuate. The recent release of the , which forecasts and analyze the global oil market, shows that more global markets are starting to say the word recession. And whether or not a recession actually materializes, the energy price environment has shifted in ways that will take multiple quarters, and maybe years, to unwind. For corporate tax departments, the question isn’t whether this changes their planning, it’s whether they’ve caught up yet.

Which scenario-modeling is most worth it?

Most ominously, nobody knows how this all ends, and that’s exactly why your tax team may need more than one base case.

The optimistic read is a short, sharp shock 鈥� prices spike, some flows resume, upstream books a windfall quarter, and consuming-country governments start muttering about excess profits taxes. Messy, but manageable.

The harder scenario is prolonged disruption: Hormuz remains constrained for months, along with repeated infrastructure hits with resulting rerouting that permanently shifts where profits land and which entities suddenly have a taxable presence for which they didn’t plan. Not surprisingly, transfer pricing and permanent听establishment听(PE) exposure get complicated fast.

Add to the mix, by the Organisation for Economic Co-operation and Development (OECD) that multinational corporate tax departments are still required to adhere to and now plan for how it may interact and intersect with the other two scenarios.

The policy environment is a mess, but in a very specific way

Here’s what makes this cycle different from 2008 or 2014: Governments are pulling in opposite directions simultaneously. The United States has pivoted hard toward energy dominance 鈥� domestic fossils, nuclear, extraction incentives. Meanwhile, BEPS 2.0 is still rolling out unevenly across jurisdictions, which means your organization鈥檚 effective tax rate in any given country depends heavily on where it sits in the implementation timeline.

Throw in 鈥� which historically shows up about six months after prices stay high and voters get angry 鈥� and you have an environment in which the gap between your statutory tax rate and your actual sustainable rate could widen fast if you’re not actively managing it.

5 actions tax team leaders can take now

Of course, none of these are new concepts; but in a fast-moving situation, the basics that get done quickly will beat the sophisticated that gets done late.

First, rebuild your EtR guidance around at least three commodity paths. Not as a theoretical exercise 鈥� as something your CFO can actually present to the board with a straight face.

Second, map out which legal entities are genuinely exposed to Hormuz-dependent flow volumes. Companies鈥� operations and trading teams often know this; but the tax team too often doesn’t until there’s a problem. Close that knowledge gap now.

Third, re-rank your project pipeline on a real after-tax basis. Updated incentive assumptions, global minimum tax, domestic versus cross-border production 鈥� run all the numbers again. Some projects that looked marginal six months ago may look very different now, and vice versa.

Fourth, build a windfall tax playbook before you need one. The data you’d need to defend your profit levels and capital allocation decisions takes time to pull together. Don’t leave that work until the week the legislation drops.

Fifth 鈥� and this is the one that gets skipped most often 鈥� make sure the company鈥檚 tax, treasury, and trading groups are talking to each other in real time. Hedging decisions, financing structures, physical flow changes 鈥� all of these have tax consequences, and they’re happening fast right now.

One final thought

Corporate tax departments that come out of this looking good won’t be the ones that predicted the conflict. They’ll be the ones who translated what鈥檚 happened into specific, actionable data and numbers for their leadership 鈥� presented quickly, clearly, and with their own company’s footprint in mind.

That’s the brief. Now go build it.

You can find more of our coverage of the impact of the ongoing War in Iran here

Key insights:

• • • Possibilities vs. practicality 鈥� There is a growing frustration gap between what corporate tax professionals want to achieve and what their current technological tools will allow.

    • Expectations about AI 鈥� Tax professionals have significantly accelerated the timeframe in which they expect AI to become a central part of their workflow.

    • Proactive progress 鈥� Automation is enabling a gradual shift toward more strategic, proactive tax work, although not as quickly as many tax professionals would like.

The recently released , from the 成人VR视频 Institute and Tax Executives Institute, reveals that while automation of routine tax functions is indeed enabling a long-desired shift toward more strategic, proactive tax work in some corporate tax departments, a majority of tax leaders surveyed say upgrading their department鈥檚 tax technology is still a relatively low priority at their company.

Jump to 鈫�

2026 Corporate Tax Department Technology Report

The report surveyed 170 tax leaders from companies of all sizes to find out how corporate tax professionals are using technology, overcoming obstacles, and planning for the future.

A growing 鈥渇rustration gap鈥�

In general, the report found that while many companies (especially larger ones) are actively upgrading their tax department鈥檚 technological capabilities, there is a growing frustration gap between what tax professionals know they can accomplish with more robust technologies and what their current tools allow them to do.

Adding to this frustration is a growing discrepancy between the additional budget and resources tax departments hope to get each year and the harsher reality they often face. Indeed, even though tax leaders remain optimistic that their budgets and capabilities will expand and improve in the coming years, fewer than half of the respondents surveyed said their departments received a budget increase last year, and many saw budget cuts.

Further, the report shows that the prospect of incorporating ever more sophisticated forms of AI and AI-driven tools into tax workflows is also very much on the minds of tax professionals. Even though the actual usage of AI in corporate tax departments is still relatively low, the report reveals that tax professionals now expect AI become a central part of their workflow within one to two years, much faster than they did in last year鈥檚 report.

Indeed, as the report explains, this expectation of more imminent AI adoption represents a significant shift in attitude, because most corporate tax departments are rather circumspect about how, when, and why they incorporate new tech tools into their established routines.

If today鈥檚 technological capabilities continue to accelerate, companies that have been slow to invest in the infrastructure necessary to keep pace may soon find themselves struggling to catch up with their more tech-savvy counterparts, the report warns.

Moving toward more proactive work, albeit slowly

For companies that have invested in the technological infrastructure necessary to support advanced tax technologies, the payoff is becoming increasingly evident.

According to the report, about two-thirds (67%) of tax professionals surveyed said their company鈥檚 investment in technology had enabled a shift toward more proactive tax work within their departments. This shift is particularly noticeable at large corporations, at which, unsurprisingly, investment in tax technology has been more generous.

The 2026 Corporate Tax Department Technology Report also explores other aspects of corporate tax departments, including their hiring practices, tech training, purchasing strategies, what they see as the most popular tech tools for tax, and numerous other factors that affect how tax departments operate.

You can download

a full copy of the 成人VR视频 Institute’s here

Key takeaways:

• • • Companies should act fast on refunds 鈥� Companies that paid IEEPA-based duties have potential refund claims, but statutory deadlines are ticking. Business leaders should map exposure, quantify opportunities, and file protective claims now.

    • Remember, other tariffs still apply 鈥� This decision only invalidated IEEPA-based tariffs. Tariffs based on Sections 232, 301, and 122 of the 1974 Trade Act听remain in force, and the administration is already signaling plans for new global tariffs.

    • Businesses should update their financial models 鈥� Tariff refunds flow through cost of goods sold, which affects taxable income and effective tax rates. Business leaders should review their transfer pricing models and contracts to determine which parties receive refund proceeds.

The U.S. Supreme Court’s recent ruling striking down the tariffs that the Trump Administration based on the International Emergency Economic Powers Act (IEEPA) creates immediate refund opportunities for businesses that paid billions of dollars in now-invalidated duties. However, the administration’s pivot to alternative tariff authorities means the trade policy landscape is shifting rather than settling.

Now, corporate tax and trade leaders must move quickly to preserve refund claims while building resilient strategies for the next wave of tariff changes that are already fully in motion.

What actually happened

In , the Supreme Court said last month that President Donald J. Trump went too far by using the IEEPA 鈥� a statute designed for genuine national emergencies 鈥� to impose broad, peacetime tariffs. The Court’s message was blunt: If you want sweeping tariff authority, get the U.S. Congress to give it to you explicitly 鈥� IEEPA doesn’t cut it.

This ruling invalidated the tariffs that relied solely on IEEPA, including certain reciprocal global duties and some measures targeting Canada, Mexico, and China. However, here’s the catch: Other tariff regimes 鈥� such as those outlined in Sections 232, 301, and 122 of the Trade听Act听of听1974听鈥� are still standing. Those weren’t touched by this decision, and they’re not going away.

Check out听听for more on the Supreme Court鈥檚 tariff decision here

Further, the administration isn’t sitting still either. There’s already talk of pivoting to Section 122 to impose a new 10% global tariff. So, while one door closed, another may be opening, which means the legal landscape is shifting, not settling.

Why this matters right now

There are several important factors to consider in the wake of this decision, including:

Start with the money 鈥� If your company paid IEEPA-based duties, your effective tariff rate on many imports just dropped. That , changes your margin picture, and could shift pricing dynamics across the retail, consumer goods, manufacturing, and automotive sectors.

Then there’s the refund potential 鈥� Billions of dollars were collected under tariffs that are now unlawful. The government won’t write checks automatically 鈥� indeed, the administration has already signaled it will fight broad refund claims 鈥� but for individual companies, the cash at stake could be significant.

Don’t overlook your contracts 鈥� Many commercial agreements include tariff pass-through clauses, price adjustments, and indemnities. Those provisions will determine which parties actually gets the money: the importer of record, the customer, or someone else in the chain. If you restructured your supply chain around the old tariff regime, you may need to rethink those decisions, too.

What businesses should do first

There are several steps business leaders should undertake to move forward in this new environment, including:

Map your exposure 鈥� Tax and trade teams need to pull multi-year import data by Harmonized Tariff Schedule (HTS) code, country of origin, and legal authority. Figure out which entries were hit specifically by IEEPA-based tariffs, as opposed to Section 232 or 301 duties, which again, are still in effect.

Quantify the opportunity 鈥� Calculate total IEEPA duties paid by entity, jurisdiction, and period. Include a rough estimate of interest, prioritize the highest-value lanes, and flag any statutory deadlines for protests or post-summary corrections. Missing a deadline isn’t something you can easily fix later.

Preserve your rights 鈥� If you’ve already filed test cases or joined class actions, revisit your strategy with counsel. If you haven’t, evaluate quickly whether to file protests, post-summary corrections, or other protective claims with the U.S. Customs & Border Protection. These procedures will evolve, of course, but the clock already is ticking.

Get the right people in the room 鈥� This isn’t just a tax problem or a trade compliance problem. Stand up a cross-functional working group that includes tax, customs, legal, finance, supply chain, and investor relations. Agree on who owns what, how you’ll share data, and how you’ll communicate, especially if the refund could move the needle on earnings or liquidity.

Financial reporting and tax implications

Most importantly, you need to reassess your tariff-related balances and disclosures. If refunds are probable and you can estimate them, that may affect liabilities, expense recognition, and reserves. Even if the accounting is murky, material claims may need to be discussed in your report鈥檚 Management鈥檚 Discussion & Analysis (MD&A) section or in footnotes.

On the tax side, tariff refunds and lower ongoing duties flow through cost of goods sold (COGS), which changes taxable income and your business鈥檚 effective tax rate. Timing matters: When you recognize a refund for book purposes may not match when it hits for tax, creating temporary differences that need Accounting Standards Codification 740 analysis.

And don’t forget transfer pricing. Many intercompany pricing models were built during the high-tariff period and may embed those costs in tested party margins. If tariffs fall or refunds materialize, those models and the supporting documentation may need updates. Review intercompany agreements that allocate customs and tariff costs to make sure they align with both the economics and the legal entitlement to possible refunds.

Think beyond the refund

Yes, the immediate focus is on getting your company鈥檚 money back and staying compliant 鈥� but this is also a moment in which more strategic thinking is required, including:

Run scenarios 鈥� Business show run their models to see what happens if IEEPA tariffs disappear and aren’t fully replaced. Model what happens if a broad 10% global tariff lands under Section 122. Model what happens if country- or sector-specific measures expand. For each scenario, stress-test your gross margin, cash flow, and key supply chain nodes.

Revisit your sourcing strategy 鈥� Some nearshoring or supplier diversification moves you made under the old tariff structure may no longer make sense. Others may still be smart as a hedge against renewed trade tensions. The tax team needs to be part of these conversations 鈥� not just because tariffs affect cost, but because new structures reshape your effective global tax rate, foreign tax credit position, and your base erosion and profit shifting (BEPS) exposure.

Fix your data and governance 鈥� Trade policies can move fast and unpredictably. If you can’t quickly pull clean import data, run classification reviews, or model your exposure across scenarios, then you’re simply flying blind. Now is a good time to fix that.

The bottom line

The Supreme Court’s decision closed one chapter of the president鈥檚 tariff story, but it didn鈥檛 end it. For corporate tax and trade leaders, the message is straightforward: Grab the refund opportunity, protect your position, and use this moment to build a more resilient strategy for whatever comes next.

Because if there’s one thing we’ve learned, it’s that the next round of tariff changes is already on its way.

For more on the impact of tariffs on global trade, you can download a full copy of the 成人VR视频 Institute鈥檚 recent 2026 Global Trade Report听here

Key takeaways:

• • • Tax departments lack resources and confidence 鈥� More than half (58%) of tax departments are under-resourced, and 59% are not confident that they can upgrade their tax technology over the next two years.

    • Under-resourced departments incur more penalties 鈥� At least half of respondents from under-resourced tax departments say their departments incurred penalties over the past year, compared to only about one-third of those from properly resourced departments.

    • Making the shift to proactive planning and value creation 鈥� For many tax departments, the winning model blends in-house expertise, targeted external support, and a coherent tech/AI stack that allows teams to shift from tactical compliance to proactive planning and strategic value creation.

Under-resourced corporate tax departments spend more of their budget on external support compared to well-resourced teams 鈥� yet they’re more likely to incur penalties and less confident in forecasting, according to the 成人VR视频 Institute鈥檚 .

Given this, the problem isn’t a lack of spending 鈥� it’s the operating model. With respondents from 58% of tax departments saying they are under-resourced, 59% saying they lack the confidence needed to upgrade their existing tax technology over the next two years, and most spending more than half their time on reactive compliance work when they’d prefer to focus on strategic planning, clearly the gap between ambition and reality has never been wider.

The answer isn’t working harder or throwing more money at consultants, however. It’s building a hybrid ecosystem of people, platforms, and partners designed to shift capacity from firefighting to foresight.

The Groundhog Day problem

Every year feels the same: New tax legislation (such as the One Big Beautiful Bill Act or Pillar 2), new compliance burdens, new geopolitical uncertainty 鈥� coupled with the same old constraints. Too much work, not enough time, and technology that lags.

When deadlines hit, under-resourced teams rely on two blunt levers: overtime and reactive outsourcing. Internal staff end up working longer hours, and external providers plug the gaps at short notice. This model is breaking departments and it鈥檚 breaking down itself.

Under-resourced departments are significantly more likely to incur penalties, with 50% of respondents saying their under-resourced department had been penalized in the past year, compared to just 34% of respondents from well-resourced departments that say that, according to the report.

Further, under-resourced department respondents said they were less confident in their ability to forecast accurately, with just 26% saying their ability to forecast accurately was “very likely” compared to 43% of well-resourced department respondents. Ironically, under-resourced departments also spend more on external support as a percentage of budget (44%) compared to 37% for well-resourced departments. Clearly, spending more doesn’t solve structural problems 鈥� it often masks them.

Meanwhile, tax professionals report spending more than half their time on tactical or reactive work, even though they would prefer to spend up to two-thirds of their time on strategic analysis. Not surprisingly, when the team is locked into manual reconciliations and last-minute fixes, it’s nearly impossible to influence business decisions or shape strategy.

Why 鈥渁ll in-house鈥� or “all outsourced” no longer works

When more work is moved onto the plates of the internal tax team, all in-house can often come to mean all heroics 鈥� talented people drowning in compliance volume with no time to use the analytical tools already on their desks. Conversely, all outsourced risks hollowing out the department鈥檚 institutional knowledge and weakening its seat at the table.

A hybrid model asks better questions: What kind of work is this, and where does it create the most leverage? These questions can be used to determine where and to whom work should go. For example, high-volume, rule-based, recurring tasks are prime candidates for automation, shared services, or managed services under strong tax oversight; while complex, judgment-heavy, strategically sensitive work should remain anchored in-house, with external advisors extending capacity and offering specialized insight.

Thus, the best model for a modern corporate tax department is a hybrid ecosystem 鈥� not a fixed organizations chart, but a deliberate blend of internal expertise, enabling technology, and external capability partners.

Four layers of the hybrid ecosystem

This hybrid ecosystem can be delineated into four layers, each bringing their own insight and value:

1. 1. 1. People and roles redesigned 鈥� High-performing tax functions invest in analyst and tax-tech roles that connect tax to enterprise resource planning (ERP) systems, data hubs, and analytics, thus freeing technical experts from manual data work. Senior professionals then become embedded advisors to finance, treasury, and the business, not just compliance reviewers.
      2. Processes segmented into “run” and “change” 鈥� The biggest barriers to strategic work are excessive volume, heavy compliance burdens, limited resources, and time pressure. Modern tax departments respond by explicitly segmenting work in which run the business processes are documented, standardized, and increasingly automated or pushed into shared or managed service models. Change the business work remains tightly linked to senior tax staff.
      3. Technology becomes the data spine 鈥� More than half of respondents say they expect above-normal increases in their tax technology budgets, and more than half say their main resourcing strategy is introducing more automation. The goal isn’t collecting point solutions; rather, it’s building a coherent data spine that includes ERP integration, tax-specific data models, consistent workflow tooling, and strategic platforms that flex as regulations shift.
      4. AI act as an accelerator 鈥� Two-thirds of tax departments aren’t yet using generative AI (GenAI), according to the report. And among the one-third that are, usage clusters around research, document summarization, drafting, and some analytical support. The next step up the AI chain is for departments to move from individual experiments to standardized, governed workflows that scan legislation, prepare first drafts of memos, or interrogate large data sets for anomalies.

What high-performing hybrid tax departments do next

Departments that feel well-resourced, allocate more time for their professionals to conduct proactive work, and invest deliberately in technology and skills are significantly more confident in their ability to forecast accurately, avoid penalties, and minimize tax liabilities, the report shows.

Indeed, these high-performing hybrid tax departments:

• • • invest ahead of crises in people, tech, and processes
    • treat external providers as capability partners, not emergency relief
    • actively protect time for strategic work by automating or outsourcing routine tasks
    • insist on a durable seat at the strategy table, not just one for compliance reporting
    • experiment with automation and AI in focused, repeatable use cases

It is worth noting that smaller companies (those under $50 million in annual revenue) and the largest one (those with more than $5 billion in revenue) are leading the way by securing leadership buy-in early and leveraging specialized external expertise rather than trying to build everything in-house. Midsize companies, by contrast, are more likely to rely on in-house teams to lead automation efforts and less likely to use third-party vendors 鈥� a cautious approach that risks having them fall too far behind to catch up.

The message: Design the ecosystem, don’t just work harder

For corporate tax professionals, the message may be harsh but hopeful: You cannot work your way out of structural constraints by effort alone. Rather, a well-designed hybrid ecosystem can turn those constraints into a catalyst that will allow the department to deliver more value to the business. In fact, the modern corporate tax department is hybrid by necessity; but the question is whether it’s hybrid by design 鈥� or just by accident.

You can learn more about the challenges facing modern corporate tax departments here

Key insights:

• • • The Supreme Court decisively limited presidential tariff power under IEEPA鈥擳he decision held that the statute鈥檚 authority to 鈥渞egulate importation鈥� does not include the power to impose tariffs, especially absent clear congressional authorization for actions of major economic significance.

    • The ruling creates major uncertainty around refunds of already鈥憄aid IEEPA tariffs鈥� There is more than $175 billion potentially at stake and no clear, orderly mechanism yet for determining who is entitled to refunds or how they will be administered.

    • Tariffs are not ending but shifting to slower, more constrained legal authorities 鈥� As the administration pivots to statutes like Sections 232 and 301 that impose procedural hurdles and limits, it is likely to result in continued trade volatility rather than relief for businesses.

In a 6鈥�3 ruling handed down February 20 in Learning Resources, Inc. v. Trump, the U.S. Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize President Donald Trump to impose tariffs. For businesses that have spent the past year navigating a dizzying storm of rate changes, exemptions, and modifications 鈥� sometimes shifting within days of each other 鈥� the ruling offers a measure of vindication.

However, don’t exhale just yet. The decision is likely to produce more confusion and instability in the near term, not less. The IEEPA tariffs may be legally dead, but the trade policy fight is very much alive, the refund process is an open question, and the administration is already pivoting to Plan B. For businesses trying to plan around a coherent trade regime, the ground has shifted again 鈥� it just shifted in a different direction.

Shortly after the announcement of the Supreme Court鈥檚 ruling, President Trump announced that his is planning to invoke new trade authorities and potentially levy new, across-the-board tariff on US trading partners. As of press time, the White House declined further comment but had tentatively scheduled a news conference for later Friday afternoon.

Here’s what happened, what it means, and what comes next.

The Court鈥檚 ruling

Chief Justice John Roberts, writing for the majority, framed the case around a simple but consequential question: Can two words 鈥� regulate and importation, separated by 16 other words in IEEPA’s text 鈥� support President Trump’s claim to his ability to impose tariffs of unlimited amount, duration, and scope on imports from any country?

The answer, from the Court鈥檚 majority is No.

The Court’s reasoning proceeded along two tracks. First, three justices 鈥� Chief Justice Roberts, and Justices Neil Gorsuch and Amy Coney Barrett 鈥� invoked the major questions doctrine, the principle being that executive actions of vast economic and political significance require clear congressional authorization. They found none in the IEEPA. As Roberts wrote, the President must “point to clear congressional authorization” to justify his assertion of tariff power. “He cannot.”

If the past year has taught businesses anything about trade policy, it’s that certainty is now a luxury item.

Second, and commanding a full six-justice majority, the Court worked through IEEPA’s text and concluded that the word regulate simply does not encompass the power to tax. The U.S. Code is full of statutes authorizing agencies to regulate various things, but the government, in its arguments before the Court, could not identify a single one in which that power has been understood to include taxation. In one of the opinion’s sharpest lines, the majority expressed skepticism “that in IEEPA 鈥� and IEEPA alone 鈥� Congress hid a delegation of its birth-right power to tax within the quotidian power to ‘regulate.'”

What the ruling does not say

Here is where businesses may need to pay close attention: The Court said nothing about refunds of tariffs already paid.

Justice Brett Kavanaugh, writing in dissent, flagged the looming chaos directly. “The Court’s decision is likely to generate other serious practical consequences in the near term,鈥� Justice Kavanaugh wrote. 鈥淩efunds of billions of dollars would have significant consequences for the U.S. Treasury鈥� . [T]hat process is likely to be a ‘mess’鈥� . Because IEEPA tariffs have helped facilitate trade deals worth trillions of dollars鈥� the Court’s decision could generate uncertainty regarding various trade agreements.”

Check out for more on the Supreme Court鈥檚 tariff decision here

That mess is now a real, operational problem. There is more than $175 billion in IEEPA tariff collections at risk, according to a estimate released today. Nearly 1,000 companies had already filed preemptive refund claims with the Court of International Trade (CIT) before today’s ruling. Indeed, the CIT has indicated it has jurisdiction to order reliquidation and refunds, and the government has stipulated it won’t challenge that authority.

However, the mechanics 鈥� who gets paid back, how much, and when 鈥� remain deeply uncertain. Some importers passed tariff costs downstream to their customers or absorbed them into pricing adjustments that can’t easily be unwound. For many businesses, the refund question will be less a windfall than a logistical headache.

What the Administration might do next

Make no mistake, the White House took a significant blow today. The IEEPA was the administration’s most flexible and powerful tariff instrument and the tool that let the President impose duties instantaneously, on any trading partner, at any rate, with no procedural prerequisites. That tool is now gone.

However, as mentioned, the administration signaled immediately that it intends an end-around in order to keep as many tariffs in place as possible. the United States would invoke alternative legal authorities, including Section 232 of the Trade Expansion Act (national security tariffs), Section 301 of the Trade Act of 1974 (unfair trade practices), and other statutory provisions. None of these alternatives offer the speed and blunt-force flexibility that the IEEPA provided, however, and they may not replicate the full scope of the current tariff regime in a timely fashion.

Shortly after the announcement of the Supreme Court鈥檚 ruling, President Trump announced that his is planning to invoke new trade authorities and potentially levy new, across-the-board tariff on US trading partners.

Justice Kavanaugh’s dissent, notably, conceded the point while framing it sympathetically: “In essence, the Court today concludes that the President checked the wrong statutory box by relying on IEEPA rather than another statute to impose these tariffs.”

That framing understates the practical significance. The alternative statutes each come with procedural requirements 鈥� agency investigations, public hearings, durational limits, rate caps 鈥� that IEEPA’s emergency framework did not impose. Section 122, for instance, caps tariffs at 15% for 150 days. Section 232 requires an investigation and report from the U.S. a Commerce Department. Section 301 demands a formal determination by the U.S. Trade Representative. These are not insurmountable hurdles of course, but they are hurdles and they will take time.

What businesses should do now

If the past year has taught businesses anything about trade policy, it’s that certainty is now a luxury item. Today’s ruling doesn’t change that; rather, it just changes the axis of uncertainty. Here’s what any organization impacted by trade should be thinking about:

• • Review your tariff exposure immediately 鈥� Understand which of your import duties were collected under IEEPA authority compared to the other statutes (Sections 232, 301, 201). Only IEEPA tariffs are affected by today’s Court ruling. Section 232 tariffs on steel, aluminum, autos, and other goods remain fully in place, as do Section 301 tariffs on Chinese imports. For many importers, a significant portion of their tariff burden will not change. For others, it may change everything.
  • Engage trade counsel on refund claims 鈥� If you’ve paid IEEPA duties, the clock is ticking. The CIT has a two-year statute of limitations on refund claims, running from the date the tariffs were published. For the earliest IEEPA tariffs (the fentanyl-related duties on Canada, Mexico, and China from February 2025, for example), that window is already narrowing. If you haven’t filed a protective claim yet, consult with counsel now.
  • Prepare for replacement tariffs 鈥� The administration has made clear it intends to reimpose tariffs under alternative authorities. Thus, the effective tariff rate is not going to 0%. Even without IEEPA tariffs, estimates suggest the average rate would settle around 9%, still far above the roughly 2% that prevailed before the beginning of President Trump’s second term. Businesses should map out scenarios to plan for a period in which IEEPA tariffs are lifted but gradually replaced by duties under other statutes, potentially with different rates, different product coverage, and different country-specific treatment.
  • Monitor trade deal stability 鈥� Many of the bilateral and multilateral trade agreements negotiated over the past year 鈥� with the United Kingdome, the European Union, Japan, South Korea, and others 鈥� were structured around tariff levels built greatly upon the IEEPA. The legal basis for those arrangements is now uncertain. Watch for renegotiations, modifications, or lapses in these existing frameworks.
  • Build flexibility into supply chain planning 鈥� This is the hardest and most important advice. The trade policy environment is not returning to a stable equilibrium anytime soon. Today’s ruling is the end of one chapter, but the broader story 鈥� of a political system wrestling with how much tariff authority the President should have 鈥� is far from over. The administration will test the boundaries of its remaining statutory tools. And the courts will almost certainly be called upon again.

Taking in the bigger picture

For businesses, the practical takeaway from today鈥檚 Court order is more pedestrian but no less important: Strap in. The tariff landscape is shifting again, the refund process will be complicated, and the administration will find another way to pursue its trade objectives. Today brought clarity on the law, but clarity on the market is still a long way off.

For more on the impact of tariffs, you can download a full copy of the 成人VR视频 Institute鈥檚 recent听听here

Key takeaways:

• • • Ways of achieving growth has changed 鈥� Sustainable growth now depends less on raw revenue and more on improving income per partner through smarter leverage, intentional service mix, and disciplined pricing.

    • Proactive firms will be better positioned 鈥� Firms that adopt data-driven pricing, bundled offerings, and subscription models will be better positioned to communicate value, raise fees confidently, and protect margins.

    • Differentiators are shifting 鈥� Leadership depth, culture, and succession planning are emerging as decisive differentiators as demographics shift, private equity reshapes the tax market, and next-generation partners step into control.

Tax, audit & accounting firms are still growing, but not all that growth is reaching the bottom line 鈥� indeed, 2026 is shaping up as a separate or be separated moment for many tax firm leaders. To sustain income per partner while the market shifts, firm leaders need to be far more intentional about how they grow, price, staff, and position their tax practices.

Here are five important ways that tax firm leaders can ensure their bottom-line growth keep pace with their top-line revenue:

1. Be deliberate about how you grow

Revenue is rising, but margins are under pressure. For example, for firms with revenue of more than $2 million, revenue grew 7.9%, yet income per equity partner (IPP) increased only 3.2%. This may imply that although firms are bringing in more money, the remaining profits available to distribute to equity partners isn鈥檛 growing at the same rate. This could mean that it鈥檚 costing firms more to generate more revenue possibly because expenses are eating into margins.

Meanwhile, 13.9% of total growth for firms whose revenue is more than $2 million now comes from mergers, and for firms with revenue of more than $20 million, more than one-fifth of growth is merger-driven.

For growth strategy, leaders should clarify their organic growth plans in light of this robust M&A drive, deciding when acquisitions are truly about capacity, specialization, or geography and when they are merely propping up lagging organic growth.

Leaders need to protect IPP metrics by focusing relentlessly on revenue per partner and revenue per person as primary levers, rather than chasing top-line growth for its own sake. Leaders also need to build optionality 鈥� with private equity, mega-firm consolidators, and independents all active, factors such as succession, capital, and ownership design have become core strategic decisions that can no longer be left to chance.

2. Treat pricing as a growth discipline

In the 成人VR视频 Institute’s pricing report for tax, audit & accounting firms, 64% of decision-makers said their firms saw revenue increases, but only 45% reported increased profits 鈥� a clear indication of margin compression. Further, just about 1-in-5 professionals said they feel 鈥渉ighly confident鈥� that their firm鈥檚 current pricing reflects the expertise of its professionals.

To be sure, key pricing work now involves moving beyond what the market will bear. While hourly billing still dominates (according to the report firms said over 40% of client engagements are billed on an hourly basis) 鈥� value-aligned methods such as fixed fees, subscriptions, and bundled packages are strongly associated with higher pricing confidence and a firm’s greater ability to raise fees.

To excel in this area, tax firm leaders need to use data rather than their gut. Although only 30% of respondents said their firm regularly benchmark their pricing against competitors, leaders overwhelmingly say better market intelligence would increase pricing confidence. Also, firms should expand subscription and bundle pricing options, since respondents form subscription-billing firms report significantly higher confidence that their pricing reflects value. Indeed, many firms using bundled packages have raised prices 10% to 24% or more over the past two years.

3. Build a capacity model that scales

The Rosenberg data is blunt: The fastest path to higher income per partner is not logging more partner hours 鈥� it is using smart leverage and stronger rates. Elite tax firms (those with IPP above $800,000) generate roughly $3.9 million in revenue per equity partner and maintain staff-to-partner ratios of around 17:1.

Several capacity dynamics matter in practice. Leverage drives profitability, for example, and those firms that have staff-to-partner ratios above 10 report IPP roughly double that of firms with ratios below 3, even though they may carry higher salary percentages.

Further, outsourcing has become mainstream. More than 4-in-10 firms (42%) with more than $2 million in revenue now outsource full-time equivalent (FTEs) employees, a figure that rises to 63% among firms with more than $ 20 million dollars. Interestingly, turnover has eased to about 11%, the lowest for the industry in years, but expectations have shifted as firms intentionally reduce average billable hours per staff member to prioritize sustainable workloads.

In fact, the key growth question is no longer Can we find the work? but rather Can we design a capacity model 鈥� onshore, offshore, AI-enabled 鈥� that supports higher rates without burning out our people?

4. Formalize strategy, marketing & service mix

Firms with written strategic plans earn about 4.5% more IPP than those without, according to the data, and firms with a formal marketing plan enjoy about 9% higher IPP. The most profitable firms are also more intentional about service mix, tilting toward advisory and financial services.

Growth-enabling practices start with written strategic and marketing plans. Firms that document these plans consistently outperform their peers, particularly when navigating private equity interest, AI adoption, and succession decisions. Many leading tax firms are deliberately shifting from compliance to advisory, reducing their reliance on commodity tax compliance and expanding into higher-value advisory work to drive stronger profitability. These firms are also packaging and communicating value more effectively by bundling compliance and advisory services into tiered packages, which in turn gives them greater ability to raise fees and justify premium positioning in the market.

5. Invest in leadership, culture & succession

Growth without leadership depth is fragile, especially in the tax profession in which the average partner age has remained high. Most recently, however, the average partner age has dipped slightly to about 52 years old as more retirements occur. And female partners now account for roughly one-quarter of partner groups overall, showing progress but also a persistent equity gap.

For many firms, succession remains a primary concern, and leadership-related growth priorities begin with treating succession as strategy, not an HR project. More firms are revisiting buy-in levels, which average around $133,000, and are experimenting with non-equity roles and alternative practice structures to create more flexible pathways to ownership. At the same time, leaders must protect and modernize their firm culture, recognizing that poorly managed PE transactions, rigid return-to-office policies, and underinvestment in technology-forward talent can quickly erode the very engines of growth they depend on.

Additionally, firms are elevating the managing partner role. In larger practices, managing partners鈥� chargeable hours are now meaningfully lower, reflecting an intentional shift toward having that role work on the business 鈥� strategy, talent, pricing, and M&A 鈥� rather than in it.

For tax firm leaders, these five considerations form a practical checklist for 2026 planning. Grounding each strategic initiative in data and taking visible action can help ensure that the next wave of growth shows up not just in revenue, but in sustainable, rising income per partner.

You can download a copy of the 成人VR视频 Institute’s pricing report for tax, audit & accounting firms, here