Navigating the 2026 Global Tax Frontier: Strategic Wisdom from Magnolia Mabel Movido, Partner, Head of International Tax, Wipfli
Magnolia Movido, Partner & Head of International Tax, Wipfli
This blog post provides a deep dive into the insights shared by Magnolia Mabel Movido, Partner and Head of International Tax at Wipfli, during the IBCircle Global Networking event on January 14, 2026.
In a global landscape that has shifted from the volatile and uncertain to the "BANI" framework - Brittle, Anxious, Non-linear, and Incomprehensible -businesses are searching for stability in the one place it is rarely found: the tax code. At the recent IBCircle gathering, Magnolia Mabel Movido provided a vital roadmap for the year ahead, detailing transformative U.S. legislation, international diplomatic "reprieves," and the startling way tax authorities are now using artificial intelligence.
For leaders and investors, Movido’s message was clear: While the complexities of 2026 are immense, the newly enacted "One Big Beautiful Bill Act" offers substantial strategic opportunities for those prepared to be proactive.
1. The "One Big Beautiful Bill Act": A Gift to U.S. Industry
The cornerstone of Movido’s presentation was the "One Big Beautiful Bill Act," which was signed into law on July 4th. This legislation serves as a massive win for domestic operations, particularly those in the capital-intensive manufacturing sector.
Key provisions include:
• 100% Bonus Depreciation: In a major reversal of previous plans, 100% bonus depreciation has been reinstated and made permanent. Under prior law, this was scheduled to drop to 20% in 2026 and hit zero by 2027.
• Domestic R&E Expensing: In a move to bolster American innovation, companies can now fully expense domestic R&E costs immediately. This replaces the previous requirement to capitalize and amortize these costs over five years.
• The SALT Deduction Increase: For individuals and small business owners, the State and Local Tax (SALT) deduction cap—a highly contested area of law—has been increased from $10,000 to $40,000**.
• Permanent Flow-Through Relief: The Section 199A (QBI) 20% flow-through deduction has officially been made permanent, providing long-term certainty for eligible businesses.
The defining legislative event of the past year was the signing of the "One Big Beautiful Bill Act" on July 4th. According to Movido, this law is a landmark win for the manufacturing sector and domestic innovators, reversing several planned tax hikes and making critical deductions permanent.
Reinstating 100% Bonus Depreciation
One of the most significant wins for capital-intensive businesses is the return of 100% bonus depreciation. Under previous tax trajectories, depreciation was scheduled to plummet to just 20% in 2026 before disappearing entirely in 2027. The new Act reinstates the full 100% benefit, allowing businesses to immediately deduct the cost of eligible assets, thereby significantly improving cash flow for 2026.
The R&E Expensing Pivot
Innovation receives a massive boost under the new law. Previously, companies were forced to capitalize and amortize domestic R&E costs over five years. Now, businesses can fully expense domestic R&E costs in the year they are incurred. Movido noted a critical distinction, however: foreign R&E must still be capitalized and amortized over a 15-year period, creating a strong incentive to keep research and development operations within U.S. borders.
Permanence and Relief: Section 199A and SALT
The Act also addresses long-standing uncertainties for small businesses and individuals:
• The 20% QBI Deduction: The Section 199A qualified business income flow-through deduction has been made permanent, providing long-term certainty for eligible business owners.
• SALT Cap Increase: The State and Local Tax (SALT) deduction, a "highly contested" area of law, saw its cap increased from from $10,000 to $40,000**.
2. Avoiding the "Revenge Tax" and the G7 Reprieve
For foreign companies operating in the U.S., the threat of Section 899 "Revenge Tax" loomed large throughout 2025. These taxes were designed to target countries deemed to be taxing U.S. companies unfairly.
Movido shared the "great news" that Section 899 was not included in the One Big Beautiful Bill Act. This omission potentially saves foreign companies billions of dollars and prevents a major escalation in international trade tensions.
Furthermore, the G7 "side-by-side deal" announced in early January 2026 provides a critical reprieve regarding the 15% global minimum tax. While the global minimum tax remains in effect and compliance may still be required for US parented companies, this deal offers relief for U.S. multinationals, and Movido noted that tax authorities as far away as France and other European countries have signaled their support for this collaborative result.
3. Remote Work and the "Thailand Trap"
The post-COVID era has cemented the "work from anywhere" culture, but Movido warned that this flexibility creates hidden tax traps. If a US employee decides to work from a foreign location without proper planning, it could inadvertently create a "Permanent Establishment" (PE) for the U.S. employer, triggering local tax obligations.
To address this, the OECD recently issued guidance clarifying these boundaries:
• The 50% Threshold: If an employee spends less than 50% of their time in a foreign jurisdiction within a 12-month period, it generally does not create a PE.
• Commercial Rationale: Even if the 50% threshold is crossed, a company may be exempt if they can prove a valid commercial reason for the arrangement.
Although this issuance may be helpful, many practitioners are still waiting for further details on this guidance to ensure taxpayers are able to comply.
4. Tariffs: The "Here to Stay" Reality
Movido, who jokingly admitted to losing sleep over the tariff landscape since February 2025, emphasized that tariffs are now a permanent fixture of global trade strategy.
While the Supreme Court is currently reviewing the legality of IEEPA bilateral tariffs, Movido’s forecast remains firm: Section 232 tariffs (aluminum and steel) and Section 301 tariffs (Chinese imports) are not going away. Even as Customs and Border Protection (CBP) prepares for potential electronic refunds through new interim regulations, businesses should plan for a future where trade barriers remain high.
5. AI: The Rise of the Predictive Auditor
Perhaps the most striking insight from Movido’s presentation was the evolution of tax enforcement through Predictive AI. Unlike Generative AI, which can "hallucinate," Predictive AI is being used by governments to cross-reference data and find anomalies.
The French Swimming Pool Example Movido highlighted a recent case where French authorities used aerial surveillance and AI to analyze photos of residential properties. By comparing these images to tax declarations, they discovered 20,000 undeclared swimming pools, instantly generating significant property tax collection. This serves as a stark reminder that global tax authorities are now using technology to "see" things that human auditors would miss.
Strategic Takeaways for 2026
To thrive in this "BANI" world, Movido urged executives to adopt a four-point strategy:
1. Prioritize Intangible Property (IP): IP and supply chain planning should be at the top of the 2026 priority list.
2. Verify AI Output: While Movido encourages the use of AI for efficiency, she warns that you must verify every result to ensure the system isn't "hallucinating".
3. Global Literacy: Leaders must understand global trade policies and the 15% global minimum tax to minimize risk.
4. Proactive Planning: Uncertainty is the only constant. Success in 2026 will be defined by those who are proactive in their strategy rather than reactive to audits.
As Movido concluded, being a "positive person" in a complex world requires having the right data and the right plan. By leveraging the benefits of the One Big Beautiful Bill Act and staying ahead of AI-driven enforcement, businesses can turn tax complexity into a competitive advantage.
Clarifying Questions to Enhance Your Strategy
• Are you currently tracking where your remote employees are spending their time to ensure you minimize Permanent Establishment risk to your company?
• Given the new 100% bonus depreciation and domestic R&E expensing, have you reviewed your 2026 capital expenditure plans to maximize these immediate tax benefits?
• How are you currently using AI in your own finance department to match the detection capabilities of global tax authorities?
• Are you affected by the tariff situation and if so, have you recently considered any changes to your global supply chain?