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On September 28, 2026, the Illinois Department of Revenue (the “Department”) released draft proposed rules (the “Draft Proposed Rules”) implementing the Digital Asset Tax Act (the “Act”), which was enacted as part of Senate Bill 3019. Notably, the Draft Proposed Rules have not yet entered Illinois’ formal rulemaking process and the Department is accepting comments through October 30, 2026. The Act imposes a 0.2% tax on the value of a digital asset involved in a…

On June 16, 2025, Illinois Governor J.B. Pritzker signed House Bill 2755 (“H.B. 2755”) into law, which includes comprehensive amnesty programs covering taxes administered by both the Illinois Department of Revenue (the “Department”) and the Office of the Secretary of State of Illinois (the “Secretary of State”).  The legislation also introduces a new amnesty program for remote retailers under the state’s Remote Retailer Occupation Tax.  Under each program, in exchange for payment of any outstanding…

On May 31, 2025, the Illinois General Assembly passed HB2755 as part of the FY2026 budget bill, which contains a number of significant tax changes to the Illinois Income Tax Act and other taxes. Governor Pritzker appears set to sign the budget before July 1st. Major changes made by HB2755 include: (1) expanding the corporate income tax base with provisions specifically targeting multinational corporations, (2) expanding the Hotel Operator’s Occupation Tax (“HOOT”) tax base by…

In an order released in July 2021, the Illinois Tax Tribunal denied a taxpayer’s motion for summary judgment in a “unitary business” case, finding that there were disputed issues of fact as to whether the taxpayer was engaged in a unitary business with a company that the taxpayer sold.  See Christopher v. Illinois Dep’t of Rev., 19 TT 131 (Ill. Tax Trib. Nov. 24, 2020, released July 2021).  The taxpayer, T. Christopher Holding Company (“Holding Company”), claimed that it was not unitary with Vogue International, LLC (“Operating Company”), and thus its gain from the sale of Operating Company could not be included in Holding Company’s Illinois business income under U.S. constitutional principles and Illinois law.  However, the Tribunal found that the Illinois Department of Revenue (“Department”) had presented sufficient evidence to establish a disputed issue of material fact that rendered summary judgment on this issue inappropriate.