DOR’s Guidance on 2026 Florida Tax Legislation

Florida DOR Begins Explaining the 2026 Tax Law Changes

The Florida Department of Revenue has released several Tax Information Publications addressing tax legislation enacted during the 2026 legislative session. For Florida SALT practitioners, the guidance is useful not only because it identifies what changed, but because it begins to show how the Department intends to administer those changes in practice.

The recently issued guidance covers several different tax areas. TIP 26C01-01 addresses Florida’s annual adoption of the Internal Revenue Code for corporate income tax purposes. TIP 26A01-07 addresses the Florida Tax Credit Scholarship Program Motor Vehicle Sales Tax Credit. TIP 26A01-04 addresses a sales tax exemption for admissions to certain professional tennis tournaments. TIP 26A01-05 addresses the sales tax exemption for portable fuel containers. TIP 26B04-01 addresses documentary stamp tax relief for certain alarm-system financing arrangements. 

For businesses, CPAs, and tax counsel, the practical question is not simply what the Legislature enacted. The more important question is how those provisions affect filing positions, taxability determinations, exemption coding, credit planning, documentation, and, in some cases, amended return decisions.

TIP 26C01-01 Deserves Close Attention for Corporate Income Tax Planning

It is worth paying particular attention to TIP 26C01-01, which addresses Florida’s annual adoption of the Internal Revenue Code. Florida’s corporate income tax system generally begins with federal taxable income, so annual IRC conformity legislation can have direct consequences for Florida corporate income tax reporting.

In TIP 26C01-01, the Department explains that sections 1 and 3 of Chapter 2026-137, Laws of Florida, amend section 220.03(1)(n), Florida Statutes, to adopt the Internal Revenue Code retroactively to January 1, 2026. The publication also explains that Florida will generally follow the computation of federal taxable income, except for specific provisions from which Florida is decoupling.

The Department identifies several federal provisions that remain tied to the Internal Revenue Code as amended and in effect on January 1, 2025, without taking into account amendments made by the One Big Beautiful Bill Act, Public Law 119-21. Those provisions include IRC section 168(k), addressing bonus depreciation; IRC section 174(a), addressing research and experimental expenditures; IRC section 163(j), addressing the business interest limitation; IRC section 274, addressing certain entertainment and related expenses; and IRC section 179, addressing the election to expense certain depreciable business assets.

The Department also states that IRC section 168(n), addressing the special allowance for qualified production property, and IRC section 174A, addressing domestic research or experimental expenditures, are not included in Florida’s definition of the Internal Revenue Code. 

Florida Corporate Taxpayers May Need to Recompute Federal Taxable Income

For SALT purposes, one of the most practical parts of TIP 26C01-01 is the filing instruction. The Department states that a taxpayer whose federal taxable income is affected by the listed provisions will need to recompute its federal taxable income for purposes of Line 1 of the Florida Corporate Income/Franchise Tax Return, Form F-1120. The taxpayer should attach a pro forma federal return with the recomputed federal taxable income, in addition to attaching pages 1 through 6 of its federal income tax return. 

This matters because Florida taxable income does not always follow the number reported for federal purposes without adjustment. When Florida conforms selectively or decouples from particular federal provisions, the state return may require a separate analysis rather than a mechanical transfer of federal taxable income.

The Department also addresses documentation. TIP 26C01-01 states that taxpayers should retain documentation supporting the recomputed federal taxable income calculation until the tax imposed under Chapter 220, Florida Statutes, may no longer be determined and assessed under sections 95.091(3) or 220.23, Florida Statutes. 

Amended Returns May Be Required for Some Taxpayers

TIP 26C01-01 also includes amended return guidance. The Department recognizes that some taxpayers may have already filed a Florida corporate income/franchise tax return under a different basis than the one explained in the TIP. In that situation, the Department states that taxpayers should file an Amended Florida Corporate Income/Franchise Tax Return, Form F-1120X, and explain the reason for the amendment. 

The Department further states that it will work with affected taxpayers to resolve penalties imposed on amended returns that are a direct result of these items. 

For practitioners, this language is important because it gives taxpayers a clear signal to review already-filed returns and determine whether the conformity guidance changes the Florida reporting position.

Florida Tax Credit Updates Also Appear in the Corporate Tax Guidance

TIP 26C01-01 also discusses Florida business tax incentives. The publication states that the Child Care Tax Credits Program has been extended and that allocations of credit are available for an additional year through state fiscal year 2027-28 for taxpayers that establish an eligible child care facility for employees, operate an eligible child care facility for employees, or pay an eligible child care facility in the name and for the benefit of an employee.

The TIP also states that the Strong Families Tax Credit program cap is increased from $40 million to $53.1 million for state fiscal years 2026-27 and 2027-28. It also notes that certain limitations on tax credit allocations will begin with the allocations for state fiscal year 2027-28. 

For Florida businesses, these provisions may be relevant to year-end planning, estimated tax planning, and credit allocation strategy.

Motor Vehicle Scholarship Sales Tax Credit Expanded

In TIP 26A01-07, the Department addresses the Florida Tax Credit Scholarship Program Motor Vehicle Sales Tax Credit. The publication explains that purchasers of motor vehicles may make a monetary contribution of up to $105 per vehicle to an eligible nonprofit scholarship-funding organization and receive a credit against the state sales tax due when purchasing or registering a motor vehicle in Florida. 

The legislative change affects the definition of “motor vehicle” for purposes of this credit. Previously, the definition did not include a heavy truck, truck tractor, trailer, or motorcycle. Effective July 1, 2026, the term includes a heavy truck with a net vehicle weight of less than 8,000 pounds. The Department cites section 28 of Chapter 2026-239, Laws of Florida, and section 212.1832, Florida Statutes. 

Practically, this change may matter for dealers, purchasers, and advisors involved in qualifying vehicle transactions.

Sales Tax Exemption Added for Certain Professional Tennis Tournaments

In TIP 26A01-04, the Department addresses a temporary sales and use tax exemption for admissions to certain professional tennis tournaments. The TIP states that admissions to any Association of Tennis Professionals ATP Masters 1000 tournament or Women’s Tennis Association WTA 1000 tournament in Florida are exempt from sales and use tax beginning July 1, 2026, through June 30, 2029. The Department cites section 212.04(2)(a)13., Florida Statutes, and Chapter 2026-239, Laws of Florida.

This is a narrow exemption, but it is still relevant for event operators, ticketing platforms, venues, and advisors responsible for admissions tax compliance.

Portable Propane Tanks Added to the Fuel Container Exemption

In TIP 26A01-05, the Department addresses Florida’s sales and use tax exemption for portable gas and diesel fuel cans. Effective July 1, 2026, the exemption is expanded to include portable propane tanks with a capacity of 20 pounds or less. The Department cites section 212.08(7)(bbb), Florida Statutes, and Chapter 2026-239, Laws of Florida. 

For retailers, this type of change should prompt a taxability review. Businesses selling qualifying propane tanks may need to confirm that their point-of-sale systems, product codes, exemption matrices, and internal guidance reflect the updated exemption.

Documentary Stamp Tax Exemption Extended for Alarm-System Financing

In TIP 26B04-01, the Department addresses a documentary stamp tax exemption connected with the sale of alarm systems. The publication states that beginning July 1, 2024, and now extended to June 30, 2028, certain non-interest-bearing promissory notes, nonnegotiable notes, written obligations to pay money, or assignments of salaries, wages, or other compensation are exempt from documentary stamp tax when given by a customer to an alarm system contractor in connection with the sale of an alarm system and when the obligation is $3,500 or less. The Department cites section 42 of Chapter 2026-239, Laws of Florida, and section 201.21, Florida Statutes.

SALT Practice Takeaways

DOR’s 2026 guidance is not limited to one tax type. It touches corporate income tax, sales and use tax, documentary stamp tax, tax credits, and filing compliance. That makes it relevant for more than one audience inside a business.

Corporate tax teams should review TIP 26C01-01 for conformity, decoupling, pro forma return, documentation, and amended return issues. Sales tax teams should review the new and expanded exemptions affecting tennis admissions, propane tanks, and qualifying motor vehicle scholarship credits. Businesses using or offering financing arrangements should review the documentary stamp tax guidance for alarm-system transactions.

For businesses currently under audit, the guidance may also help frame whether a filing position, exemption treatment, or tax credit position should be revisited before the Department raises the issue.