BDO Talks Total Tax

Guest Notes

JR Johnson is the VP of Tax at Tenable, where he brings over 20 years of experience in tax accounting and tax compliance. Throughout his career, JR has led multiple transformative initiatives to optimize tax operations for multinational publicly traded corporations.

JR on LinkedIn

Tyler Clark is a Principal in BDO’s Digital Tax Solutions practice. He works with clients of varying sizes across multiple industries to enhance tax functions through technology, process optimization, and the implementation of third-party tax provision, compliance, and data extraction solutions.

Tyler on LinkedIn

Key Takeaways

• Think big, start small and act fast: Break transformation into manageable projects that address high-impact pain points and build momentum through early wins.

• Technology alone does not transform a tax function: Reevaluate legacy processes and use systems to their full potential rather than layering new tools onto old ways of working.

• Look inside the organization before buying something new: Existing enterprise tools and infrastructure may already provide the capabilities tax teams need.

• Make IT a strategic partner: Clearly communicate tax requirements, ask the right questions, and align objectives to unlock better data and stronger outcomes.
• Build the data foundation first: Centralized, reliable data enables more effective automation, analytics, reporting, and future AI applications.
• Use AI with purpose: Focus first on the business problem and the opportunity to automate — not on adopting AI simply because it is available.
• Stay patient, flexible and open-minded: Transformation is rarely linear, and lasting progress depends on collaboration, adaptability, and a willingness to learn.

Related Resources

• Tax Innovation Webcast Series
• From Silos to Synergy: Aligning Tax and Finance

Guest Notes

Cady Stanton is a senior reporter for Tax Notes Today Federal, covering Capitol Hill since 2023. Her beat focuses on U.S. federal tax legislation, the House Ways and Means and Senate Finance committees, IRS appropriations, and other tax developments in Congress. Her writing has previously appeared in USA Today, The Winsted Phoenix, The Washington Monthly, and The Hill. She was a National Press Foundation Paul Miller Washington Reporting Fellow in 2025 and has a B.A. from Georgetown University.

Follow Cady on X at @cady_stanton and contact her confidentially on Signal at cadystanton.31.

Key Takeaways

• Corporate tax leaders should continue monitoring year-end tax developments, including government funding negotiations, IRS funding decisions, and the potential for targeted bipartisan tax legislation.
• Major tax legislation appears unlikely before the midterms, making scenario planning and readiness for post-election activity especially important.
• IRS resource constraints could slow guidance, taxpayer service, and issue resolution, so tax departments should act quickly when matters require IRS engagement or escalation.
• Despite operational challenges, IRS enforcement remains active in targeted areas such as transfer pricing and partnerships, underscoring the need for strong documentation and audit readiness.
• Potential tax administration reforms could expand refund claim procedures and dispute resolution options, but companies should continue to use existing channels rather than wait for legislation.
• Digital asset tax proposals remain complex and uncertain, with possible implications for mining, staking, routine transactions, securities lending rules, and wash sale rules. Taxpayers should monitor the legislative process for potential planning action ahead of proposed effective dates.
• Election outcomes could reshape the tax agenda, with divided government likely to increase oversight and limit major legislation absent a significant external event.
• If Republicans retain control, reconciliation could remain the primary path for tax changes, including revenue-raising provisions, tax-exempt organization proposals, and extensions of select OBBBA provisions.

Related Resources

• Tax Policy Resource Hub
• Senate Taxwriters Approve Bill to Expand Taxpayer Protections
• Tax Committee Unveils New Crypto Tax Legislation
• Tax Legislative Roundup: Reconciliation, OBBBA Guidance Outlook, and IRS Enforcement

Guest Notes

Peter Pentland is a Tax Principal and national leader of BDO’s Accounting Methods practice, advising companies across industries on complex tax accounting method opportunities, risks, and best practices. With deep experience in areas such as inventory methods, revenue recognition, depreciation, M&A transactions, and IRS exam defense, Peter brings practical insights to help businesses navigate evolving tax rules and business environments.

Peter on LinkedIn

Key Takeaways

• Tax planning is entering a more strategic phase. One year after the passage of OBBBA, many companies are moving beyond compliance and beginning to evaluate how the law’s provisions can work together to support a multi-year tax planning strategy.
• Section 174 remains a priority planning area. The reintroduction of full expensing for domestic research and experimentation costs creates meaningful opportunities, but immediate expensing may not be optimal for every company — especially when international tax implications are considered.
• Provisions should not be evaluated in isolation. Bonus depreciation, Section 163(j), Section 174, qualified production property, and international provisions can interact in ways that materially affect tax outcomes, making integrated modeling and coordinated decision-making essential.
• The return to an EBITDA-based Section 163(j) limitation provides relief, but not a complete solution. Highly leveraged businesses and companies with significant interest carryforwards may still face limitations and should reassess planning strategies as certain interest capitalization opportunities narrow.
• International tax planning will become increasingly important in 2026 and beyond. Companies with inbound or outbound activity should evaluate how domestic planning decisions may affect international provisions, foreign tax credit considerations, and broader global tax positioning.
• Better data and technology are reshaping the tax function. As companies gain access to more complete data and improved forecasting tools, tax departments have an opportunity to shift from reactive compliance to proactive, integrated planning.
• A roadmap can help companies prioritize limited resources. Successful taxpayers are focusing first on the most immediate decisions, revisiting annual elections, and building flexible planning models that can adapt as guidance evolves.

Related Resources

• Recent ‘Renovations’ to Fixed Asset Planning: How the OBBBA Impacts Depreciation
• One Big Beautiful Bill Act Expands 100% Depreciation Expensing Opportunities
• Section 163(j) after OBBBA: Leveraging cost-recovery accounting methods
• Domestic R&E Expenditures Method Changes That Must Be Made for the 2025 Tax Year

Guest Notes

Rob Gutierrez is President and CEO of CalTax, where he leads the association’s work on California tax policy and taxpayer advocacy. With experience spanning state and local finance, California Tax Foundation research, and service on the Franchise Tax Board Advisory Board, he brings deep insight into the tax issues shaping California and influencing other states.

Rob on LinkedIn

Peter Blocker is Vice President of Policy at CalTax, where he analyzes state tax legislation, represents the organization at the Capitol, and contributes research on tax policy, government efficiency, elections, and local tax issues.

Peter on LinkedIn

Key Takeaways

• California tax policy is a year-round issue, with changes moving through legislation, budget bills, ballot measures, and last-minute amendments.
• The state budget process is increasingly shaping tax policy, creating compressed timelines and new planning considerations for taxpayers.
• SB 122 would expand California sales and use tax to prewritten software and software as a service (SaaS) beginning January 1, 2027.
• Businesses should continue monitoring credit utilization limits, including the extended $5 million cap and longer-term limitations beginning in 2030.
• California’s structural budget pressures are driving renewed interest in revenue-raising measures.
• Proposed 2026 ballot measures, including the wealth tax and related countermeasures, could materially affect California’s tax landscape.
• Tax leaders should assess potential impacts early and stay engaged as California tax policy continues to evolve.

Related Resources

• California Taxpayers Association: CalTax
• California OTA Opinion Sheds Light on Unitary Substantiation Requirements
• California Budget Updates Business Credit Limit, Creates Digital Software Tax, and Imposes Healthcare Tax
• California Moves to Subject Digital Prewritten Software to Sales and Use Tax
• California’s Billionaire Tax Proposal Would Allow Sweeping, One-Time Taxation Based on Net Worth