By Stanley Foodman
Global tax oversight is entering a new phase. The 2025–2026 cycle introduces new U.S. tax provisions, higher expectations for data accuracy under CRS 3.0 and CARF, and a renewed focus on governance as regulators coordinate more closely across jurisdictions. Institutions, family offices, and advisors will need clearer structures and integrated risk management to stay ahead.
At the 42nd International Symposium on Economic Crime in Cambridge, UK, one theme came through consistently among regulators, investigators, and global practitioners: Tax oversight is now global, coordinated, and data-driven.
The next tax season will reward institutions that prepare early and unify governance across tax, reporting, and compliance functions.
Below are the five preparation areas global clients should prioritize now.
1. Prepare for multiple TCJA outcomes and clarify 2025 exposures
Recent legislation made the TCJA individual income tax rates permanent, but several related provisions and structural elements still present planning challenges for 2025 and beyond.
Estate and gift thresholds, pass-through deduction interactions, itemized limitation rules, and foreign credit alignment remain areas where future policy adjustments are possible. Global households and cross-border structures should model exposures under multiple scenarios to ensure informed decisions about distributions, investments, and structural planning.
Early modeling is especially important for clients balancing obligations across several jurisdictions.
2. Understand how new 2025 deductions can create hidden cross-border risks
A number of new or expanded provisions take effect in 2025. While they appear straightforward, they contain technical conditions, MAGI-based phaseouts, and documentation requirements that can create challenges for global clients:
- The higher SALT cap
- The expanded car-loan interest deduction (new U.S. assembly and lien requirements)
- Updated AMT thresholds
- The new senior deduction
- Federal income-tax deductions for certain tip and overtime (still subject to FICA and typically state tax)
For multinational families, these deductions may conflict with foreign tax credit calculations or create timing mismatches between U.S. and non-U.S. reporting periods. Advisors should evaluate each client’s global profile and confirm that documentation meets audit standards.
3. Align systems with CRS 3.0 and CARF before reporting season begins
CRS 3.0 and CARF raise expectations for clarity, classification, and data integrity across institutions, family offices, and service providers that administer cross-border structures. These standards demand:
- Precise income classification
- Enhanced XML validation and schema alignment
- Consistency between FATCA, domestic reporting, and digital-asset reporting
- Stronger governance over data from onboarding through transmission
Misalignment between U.S. tax filings and CRS or CARF output will be a significant risk point in 2026. Institutions should begin mapping data to a unified taxonomy and strengthening controls now.
4. Monitor threshold changes that may trigger new reporting obligations
Global tax exposure increasingly depends on threshold-based and classification-based rules. Even minor changes can create or eliminate reporting obligations. Areas requiring attention include:
- Beneficial ownership reporting under the Corporate Transparency Act (CTA)
- U.S. foreign trust and asset reporting
- GILTI and PFIC calculations
- Withholding obligations across jurisdictions
- Updated Form 1099-K and 1099 rules
Institutions should review client structures in advance and confirm alignment across U.S. filings, CRS 3.0 output, and CARF classification to avoid cross-framework inconsistencies.
5. Strengthen governance as the core indicator of 2026 tax readiness
Governance is emerging as the primary lens regulators use to evaluate global tax oversight. Regulators want to see coordination, not separate tax, reporting, and compliance processes. What matters now is whether an institution can show how its filings connect, how its data is checked, and how its numbers reconcile across jurisdictions.
Why this matters for 2026
The next tax season will demand:
• Integrated tax, compliance, and reporting oversight
• Reliable data architecture that support global transparency
• Proactive scenario planning for TCJA-related variables
• Strong governance that demonstrates control execution
Organizations that begin early will reduce pressure later in the year and be better positioned to navigate multi-jurisdictional risk.
If you would like guidance tailored to your global tax or reporting profile, you can contact our office at info@foodmanpa.com.
