With these substantive tax changes looming, it may be simpler to point out what is not changing.
C Corp Tax Rate Remains
While C Corp tax rates are not scheduled to change, legal professionals must stay informed about the broader tax enforcement landscape.
Prior to 2018, American businesses faced a top tax rate of 35%, the highest in the industrialized world. These high taxes led to unintended and detrimental effects in business such as corporate tax inversions and businesses relocating operations out of the country. With the Tax Cuts and Jobs Act, the C Corp tax rate was permanently lowered to a flat 21%, right at the average of the industrialized world. This lower tax rate is not going away, and hopefully businesses will not resume the practices of shell-gaming their profits or offshoring their operations any time soon.
Long-Term Capital Gains Tax Rate Stays the Same
Additionally, the long-term capital gains tax rate—the tax applied to selling capital assets—is not moving from its current 23.8%, top marginal rate plus ACA surtax. This is welcome news because if the rate were going up in 2026, the market landscape may be overwhelmed with fire sales in 2025, with sellers trying to liquidate while taxes are low. If the rate were going down in 2026, the cost of capital assets over the next couple of years would increase tremendously to make up for the extra tax premium being paid before 2026. Instead of encouraging either tumultuous situation, the long-term capital gains rate is holding steady into the future.
IRS Enforcement Enhancement
While these substantive tax changes may be disruptive, the second hit of the one-two punch alluded to earlier comes with the Internal Revenue Service’s increased funding for enforcement from the Inflation Reduction Act. In late 2022, Congress authorized $80 billion of additional funding for the IRS over 10 years. Of this allotment, the IRS is expected to put $45.6 billion toward tougher enforcement, largely by hiring an additional 87,000 new revenue agents and enforcement personnel.
While there have been some political negotiations to try to reduce these new funds to the IRS, not much has been taken away from this budget increase. Indeed, when the funding and hiring are complete, the IRS will more than double its 2022 workforce. This development raises several issues:
- Who will these new IRS enforcers be targeting in the early days of the 2026 tax changes?
- How will the new enforcers’ mandate for increased revenue through increased enforcement affect the average taxpayer?
- And if large, well-paying accounting firms are having difficulty hiring qualified accountants, just who will make up the new enforcement workforce at the IRS?
The next several years may be a perilous time to plan for tax changes and engage with the newly robust IRS. Legal practitioners will need to navigate an environment of increased scrutiny and enforcement, advising clients on both compliance strategies and defense against audits or investigations.