Talking Tax

States Still Decoupling From GOP Tax Law Deep Into Filing Season

Mar 4, 2026
Scott Roberti, managing director at EY who advises on state and local tax, explains why states are still deciding whether to follow last year’s federal corporate tax changes. He discusses which federal provisions states are targeting, political standoffs in places like D.C. and Arizona, and how data-center incentives and sales/property tax reforms are shifting. Filing season remains unusually uncertain.
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ADVICE

Monitor State Guidance Before Filing

  • Do monitor state guidance closely when advising corporate clients on filings and accounting adjustments.
  • Scott Roberti says 17 states issued guidance so far and the rest are proposing changes while sessions continue.
INSIGHT

OB-3 Changes Hit States Differently Than TCJA

  • States view OB-3 differently than TCJA because OB-3 accelerates deductions rather than expanding the tax base.
  • That shift matters because states balance budgets annually and immediate expensing creates sudden fiscal pressure.
ADVICE

Plan For State Decoupling On R&E Expensing

  • Do expect and plan for state decoupling from immediate R&E expensing and retroactive federal changes.
  • Roberti notes many states are decoupling and some propose phased conformity to manage fiscal impacts.
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