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Tax PlanningDecember 19, 20257 min read

The Biggest Tax Surprises of 2025 (And What They Mean for 2026)

The Biggest Tax Surprises of 2025 (And What They Mean for 2026)

Published: December 19, 2025

Every tax year has surprises. 2025 had whiplash.

Regulations were announced, delayed, reversed, reinstated, and suspended—sometimes within weeks. Requirements that seemed certain evaporated. Benefits that seemed impossible materialized.

Here are the biggest surprises from 2025, ranked by how much they caught businesses off guard, and what they mean for your 2026 planning.

Surprise #1: The BOI Rollercoaster

The setup: Corporate Transparency Act requires businesses to report beneficial ownership to FinCEN. Seemed straightforward.

What actually happened:

DateEvent
December 3, 2024Federal court issues nationwide injunction. No filing required.
December 23, 2024Injunction lifted. Deadline: January 13, 2025. Panic ensues.
December 26, 2024Injunction reinstated. Back to no filing required.
February 18, 2025Injunction lifted again. New deadline: March 21, 2025.
March 3, 2025Treasury suspends enforcement for domestic companies.

Four reversals in four months.

Business owners who rushed to file in late December? Filed unnecessarily. Those who waited? Made the right call by accident.

The lesson: Government requirements aren't final until they're actually enforced. Keep watching FinCEN for updates, but don't panic-file for requirements that may never stick.

Current status: Domestic companies exempt. Foreign entities must still file. Final rule expected.

Surprise #2: SALT Cap Quadrupled

The expectation: The $10,000 SALT cap was supposed to be one of the TCJA provisions most likely to remain unchanged.

What happened: It jumped to $40,000 for taxpayers with AGI ≤ $500,000.

Why it's surprising:

The SALT cap limitation had become such a fixture that many tax planning strategies were built around it:

  • Pass-through entity tax elections
  • Income timing strategies
  • State residency planning

Those strategies may need revisiting.

The math that changed:

For a California business owner with $150,000 in state income taxes:

ScenarioDeductibleTax Savings (32% bracket)
Old cap ($10K)$10,000$3,200
New cap ($40K)$40,000$12,800
Additional savings$9,600

The twist: Only lasts through 2029, with 1% annual increases. Then reverts to $10,000. So it's relief, not permanent reform.

Action: Recalculate your SALT strategy. The pass-through entity election workarounds may no longer be worth the complexity.

Tax Surprises 2025

Surprise #3: QBI Permanence + $400 Minimum

The expectation: QBI deduction would either expire, get extended temporarily, or be reduced.

What happened: Made permanent. Enhanced with a $400 minimum.

Why it matters:

The 20% QBI deduction is one of the most valuable tax benefits for pass-through businesses. Its uncertain future had been creating planning paralysis:

  • Should I restructure as a C-corp?
  • Should I accelerate income before expiration?
  • How do I plan for retirement if I don't know my future tax rate?

Those questions have answers now.

The $400 minimum surprise:

Starting 2026, businesses with active income over $1,000 get at least a $400 deduction—even if 20% of their QBI calculates to less.

This helps very small or new businesses get meaningful benefit from the provision.

Action: Update your long-term tax projections. QBI permanence changes optimal entity structure calculations.

Surprise #4: Tips Become (Partially) Tax-Free

The expectation: Campaign rhetoric about "no tax on tips" would die in legislative sausage-making.

What happened: It actually passed. Up to $25,000 in cash tips can be excluded from federal income tax (2025-2028).

The fine print:

  • Only for occupations that "customarily and regularly" received tips before December 31, 2024
  • IRS published the qualifying list by October 2025
  • Income limit: $150,000
  • Still subject to FICA taxes

Why it surprised:

Political promises about eliminating taxes on specific income types rarely survive contact with reality. This one did—though in modified form.

Who wins:

  • Restaurant servers
  • Bartenders
  • Hotel staff
  • Hair stylists
  • Ride-share drivers
  • Others on the IRS list

Business owner implications:

If you employ tipped workers:

  • Payroll systems needed updating
  • Employee communications required
  • Withholding calculations changed
  • Documentation requirements increased

Action: If you have tipped employees, ensure your payroll provider has implemented the changes correctly.

Surprise #5: The Infrastructure Cost Explosion (VMware/Broadcom)

The expectation: Technology costs would continue their gradual increase.

What happened: Some financial institutions saw infrastructure costs jump 600%+ after the Broadcom/VMware acquisition.

Why it's a tax surprise:

When your core technology costs spike unexpectedly:

  • IT expense categories blow past projections
  • Budget reallocations reduce profit
  • Tax planning based on expected profitability fails
  • Capital expenditure decisions get rushed

The ripple effects:

Businesses that relied on VMware products faced an impossible choice:

  1. Pay dramatically more for the same capabilities
  2. Invest in migration to alternatives (also expensive)
  3. Cut other technology investments

Action: If you're budgeting IT costs for 2026, build in contingency for vendor pricing changes. The days of stable enterprise software pricing may be over.

Surprise #6: Real-Time Payment Fraud Explodes

The expectation: FedNow and instant payment adoption would be all upside.

What happened: Fraud followed the money—instantly.

From CSI's Banking Priorities Report:

  • 44% of banks reported card and check fraud
  • ~40% experienced fraudulent account openings
  • AI-generated scams increased sophistication dramatically

The tax angle:

Fraud losses are deductible, but:

  • Documentation requirements are strict
  • Timing of loss recognition matters
  • Insurance recovery offsets the deduction
  • Large losses may require amended returns

For small businesses:

Faster payments mean faster fraud. If you're using instant payment systems:

  • Implement real-time fraud monitoring
  • Train staff on new scam types
  • Review your cyber insurance coverage
  • Document everything for potential loss deductions

Action: Budget for fraud prevention, not just fraud response. The cost of prevention is usually deductible; the cost of unrecovered fraud is more complicated.

What These Surprises Mean for 2026 Planning

1. Build Flexibility Into Tax Strategy

The 2025 reversals prove that "certain" tax changes can evaporate. Strategies that require a specific provision to remain in effect are risky.

Better approach: Create optionality. Structure decisions so you can pivot if rules change.

2. Monitor Legislation Continuously

Annual tax planning isn't enough anymore. Major provisions changed mid-year in 2025 and could again.

Better approach: Quarterly tax check-ins. Subscribe to IRS and Treasury updates. Work with a professional who tracks changes actively.

3. Document Everything

When rules keep changing, documentation becomes your protection:

  • Why you made specific decisions
  • What information you relied on
  • When you took action
  • What you expected vs. what happened

Better approach: Keep a tax decision log. Note the date, the provision, and your reasoning.

4. Question "Common Knowledge"

The SALT cap surprise shows that conventional wisdom can be wrong. BOI showed that "requirements" can disappear.

Better approach: Validate assumptions. What everyone "knows" may not be true by next quarter.

The Silver Lining

Yes, 2025 was chaotic. But the surprises mostly broke in favor of small businesses:

  • ✅ QBI permanent (positive)
  • ✅ SALT cap raised (positive)
  • ✅ Tips exemption (positive)
  • ✅ BOI suspended (positive)
  • ✅ Higher 1099 threshold (positive)

The tax code for small businesses is more favorable heading into 2026 than most predicted at the start of 2025.

The challenge is staying informed enough to capture the benefits.


I'm Slava Akulov, CEO and Co-founder of Jupid. We're building AI that tracks tax changes and automatically applies them to your business—so you don't have to. No more surprises, just savings. Let's connect.

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