State Tax Day - Current, S.4, Georgia—Multiple Taxes: IRC Conformity Updated and Motor Fuels Tax Suspended, (Mar 25, 2026)
Georgia has enacted legislation updating its corporate and personal income tax Internal Revenue Code (IRC) conformity date, and also temporarily suspended the collection of the motor fuels tax.
IRC Conformity
The new IRC conformity date incorporates federal tax law changed enacted on or before January 1, 2026. The updated conformity date is applicable to all taxable years beginning on or after January 1, 2025.
Specific IRC Provisions
State and Local Tax (SALT) Caps.— Georgia’s State and Local Tax (SALT) deduction cap remains at $10,000, and does not conform to the new federal $40,000 cap.
Tips and Overtime.— Georgia has not conformed to the new federal provisions that eliminate taxes on tips or overtime pay.
Low-Income Housing Tax Credit (LIHTC).— Georgia will partially conform to federal LIHTC rules (IRC §42), but has set an annual cap of $100 million in credits from 2026 through 2028.
Additional Individual Conformity Provisions.— Georgia's conformity legislation also includes several provisions affecting individuals, including:
limiting casualty loss deductions to those arising from federally declared disaster events;
removing the availability of miscellaneous itemized deductions;
replacing the previous limitation on higher-income taxpayers’ itemized deductions with a new cap on the overall tax benefit those deductions may generate;
adopting federal provisions that exclude employer-provided student loan repayment assistance from taxable income;
updating the thresholds applicable to charitable contribution deductions for itemizing taxpayers; and
aligning with federal enhancements to the exclusion rules applicable to qualified small business stock.
Additional Business Conformity Provisions.— The legislation conforms to federal corporate charitable contribution limitation rules, but it declines to follow several federal business tax provisions, including:
not conforming to federal full expensing under IRC §168(k);
not conforming to federal research and experimental expenditure capitalization rules, with Georgia continuing to apply pre-TCJA full-expensing treatment;
not conforming to federal business interest-limitation provisions under IRC §163(j);
partially conforming to IRC §179 expensing limitations; and
not conforming to federal special depreciation allowance rules.
Tax Suspension on Motor Fuels
Additionally, the collection of motor fuels tax has been suspended for 60 days.
Ch. 375 (H.B. 1199), Laws 2026, effective March 20, 2026, and applicable to all taxable years beginning on or after January 1, 2026