While provisions in the One Big Beautiful Bill apply at the federal level, North Carolina has not conformed to the new law, creating notable divergences between federal and state tax treatment. To address these differences, the North Carolina Department of Revenue issued an Important Notice on January 8, 2026. Following are the key points included in the notice. 
- North Carolina has not updated its federal conformity date.
North Carolina income tax law currently conforms to the Internal Revenue Code as of January 1, 2023. As of the date of the Notice, the General Assembly has not enacted legislation to adopt federal tax law changes enacted after that date.
- Recent federal tax changes do not apply for NC purposes—yet.
For tax year 2025, federal changes enacted after January 1, 2023 must be excluded when computing North Carolina taxable income. This includes provisions in:
- The Federal Disaster Tax Relief Act of 2023, and
- The One Big Beautiful Bill Act, including updates affecting R&E capitalization and bonus depreciation.
- The General Assembly may act after the filing deadline.
Legislators are not scheduled to convene until after April 15, 2026, meaning conformity legislation, if enacted, could come after returns are due. Even then, the legislature may choose to decouple from specific federal provisions.
- Taxpayers impacted by these federal changes generally have two options to consider for the April 15, 2026 filing and payment deadline:
- File an extension, preserving flexibility while waiting for legislative action (note: extensions do not extend time to pay), or
- File the return excluding the federal changes. A reconciliation schedule will be required comparing federal law in effect for 2025 to the Internal Revenue Code as of January 1, 2023. Amended returns may be required later.
- Expect additional guidance.
- NC Department of Revenue has advised that updates will be posted on its website and disseminated through e-alerts as the situation evolves.
Click here to read the full text of the Important Notice.
Each taxpayer’s situation is unique, but our default position will be to delay all tax return filings until after April 15 when the NC General Assembly meets in session to either conform or adopt different tax legislation. All client tax returns will be extended. The extension of time to file is not an extension of time to pay and you should make payments accordingly if necessary.
The tax professionals at Gilliam Bell Moser are carefully monitoring legislative action to assess the potential impact to our clients and the upcoming tax filing season. As additional guidance or changes emerge, we are committed to keeping our clients informed promptly and helping them navigate any implications as efficiently as possible.
