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Vermont Tax Changes 2026: Act 164 Conformity | HelloBooks Vermont’s Act 164 of 2026 retroactively conforms to the 2025 federal law for 2025 returns, with decoupling from 174A, 168(n) and FDII or GILTI.

Vermont · IN-111

Vermont conforms to the 2025 federal law, with exceptions

Vermont passed retroactive conformity in 2026, so 2025 returns follow the new federal law except for a short list of business provisions.

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Vermont · IN-111

Conformity act

Act 164 (H.933) of 2026

Applies to
Tax years from January 1, 2025
Decoupled
174A, 168(n), section 250
Federal law
Pub. L. 119-21

Applies: Tax years beginning on or after January 1, 2025From IRS.gov · checked October 10, 2026

What Act 164 does

The Department of Taxes says Act 164 retroactively updates Vermont income tax law to Public Law 119-21 for tax years beginning on or after January 1, 2025, and decouples from several provisions starting with 2025.

  • Section 174A domestic research and experimental expensing.
  • Section 168(n) depreciation for qualified production property.
  • The section 250 deduction for FDII or GILTI, for C corporations.

What to check

The department’s conformity page does not say how Vermont treats bonus depreciation, section 179, or the Schedule 1-A deductions. Read the Federal Conformity Supplement and the Act before you prepare returns for business clients with large asset purchases.

FAQ

Frequently asked questions

Do Vermont business clients amend 2025 returns already filed?
Because Act 164 is retroactive to 2025, review any 2025 return filed before it passed for decoupled items such as 174A.

Sources

General information for tax professionals, not advice on a specific return. Figures are from IRS.gov on the date shown; check the current IRS instructions before filing.

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