Q3 2026 Tax-Law Review: Separate Enactment from Implementation
OBBBA was enacted July 4, 2025, not in Q3 2026. Identify actual enactments through September 30 and distinguish effective dates, guidance and proposal scenarios.
Editorial source review — November 1, 2026. This machine-generated article has been reviewed, but is not certified accurate. Source-backed corrections are incorporated where established. Other legal, survey and product claims may remain unverified; check applicable primary authorities before relying on a deadline or tax position.
Findings in the original version: EY's report covers developments through September 18, not all of Q3. OBBBA was enacted in July 2025, not newly enacted in Q3 2026.
Public Law 119-21 was enacted July 4, 2025. Its continuing implementation is relevant to 2026 provisions, but it is not a new Q3 2026 enactment. Guidance dates, statutory effective dates and enactment dates are distinct.
Do not claim a complete quarter from a partial-period alert
EY's quarterly summary reviewed here has a September 18 information cutoff. Supplement it with primary instruments for September 19–30 before treating it as a complete September 30 inventory. This article does not certify every foreign rate or state conformity change in that period.
Period-specific federal changes
Bonus depreciation was restored to 100% for qualifying property acquired and placed in service after January 19, 2025. Section 163(j) depreciation, amortisation and depletion add-backs returned for tax years beginning after December 31, 2024. Section 174A generally permits qualifying domestic R&E deductions in tax years beginning after December 31, 2024, with transition and election rules. Each provision needs its own scope analysis.
Accounting conclusions are separate
Determine whether an actual enacted measure affects current tax, ordinary deferred taxes, an uncertain position or disclosures. Do not automatically book a new DTA or DTL for future GloBE top-up taxes merely because a regime is enacted. Apply the reporting framework and the facts of the actual law.