The Issue

On September 17, 2026, the Department published its official guidance on this, covering tax returns starting with the 2025 tax year.

Our Response

The PICPA recommended that the Department clearly spell out different rules for each type of taxpayer, and only apply the federal changes where it actually has solid legal footing to do so. We also asked for more practical guidance, covering how to fill out the forms, what to do about returns already filed, how this affects 2026 estimated tax payments, and whether penalties or interest would be waived for anyone caught off guard.

Importantly, we also said that if the city wants the other tax types to follow the same federal rules, that change should go through City Council or a formal rule-making process, not just be announced through informal guidance.

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