It’s 5:00 p.m. on the interstate, and you’re sitting in heavy traffic. It’s 5:00 a.m. on a rural highway, and you’re the only conveyance without a saddle and a mane for miles. Under Massachusetts’ new vehicle mileage tax exploratory, both trips could be taxed the same. That would be a missed opportunity.
Earlier this month, state lawmakers introduced SB 2404, which would establish a task force and pilot program to explore a vehicle mileage tax. The goal is to replace the gas tax, which has seen dwindling revenue thanks to rising fuel efficiencies and electric cars. The proposed pilot would equip 1,000 volunteer drivers with mileage-tracking devices to evaluate how a per-mile fee would work in practice.
A per-mile fee is a reasonable upgrade from the gas tax. The downside of the Massachusetts proposal is that it assumes every mile driven imposes the same cost on society. But an additional vehicle on I-93 at rush hour contributes more to gridlock—and consequently emissions and lost economic productivity—than the same car cruising down a country lane at dawn.
A well-designed VMT pilot could introduce dynamic pricing, charging more during peak hours in high-congestion zones and less when roads are empty. Just look at New York. A bit over a year into the country’s first congestion pricing program, vehicle volume is down, air quality is up, and the city is on track to generate $500 million annually in net revenue.
Massachusetts should design the VMT pilot with congestion pricing in mind from first principles—testing variable rates based on time of day, road type, and even proximity to public transit alternatives. This would send a clear message: If you drive when and where it causes the most disruption and you have alternatives, you will pay accordingly.
—Andrew Leahey
Welcome to the Week in Insights for Bloomberg Tax’s latest analysis and news commentary. This week, experts analyzed tariffs’ expected impact on transfer pricing in 2026, how AI will change professional services firms’ talent development, and more.
The Exchange —It’s where great ideas on tax and accounting intersect.
Insights
IRS Keeps Focus on R&D Tax Credit Even as Agency Staff Shrinks
The research and development tax credit will remain a target of the IRS in 2026, even with staff reductions because of the potential for substantial adjustments and revenue recovery is high.
Revival of the Wealth Tax May Prompt Constitutional Challenges
This coming year will reveal whether the revival of the wealth tax remains symbolic or becomes structural. Expect congressional hearings on mark-to-market taxation, renewed state-level proposals, and inevitable constitutional challenges—possibly fast-tracked to the Supreme Court.
Digital Mandates and AI Reshape VAT Compliance Landscape in 2026
In 2026, businesses need to plan strategically, adapt to data-driven and automated processes, and integrate value-added tax into broader finance and tax processes.
Full Impact of Trump Tariffs Will Shake Transfer Pricing in 2026
The effect of the Trump administration’s tariffs, and the transactional changes sparked by the tariffs, will complicate transfer pricing compliance in 2026.
AI Quietly Rewrites Professional Services Firms’ Talent Model
Recent efforts by PwC to train new associates on AI tools are sensible and necessary responses to how quickly technology is reshaping professional work. But they also point to a deeper industry shift.
Crypto’s Rules Are Here. 2026 Will Be About Making Them Work
Companies and practitioners should expect 2026 to be less about crafting new regulations for crypto and more about refining, connecting, and operationalizing the ones already in place.
Traditional Accounting Firm Model May Shift to Special Offerings
Transformation doesn’t require overnight change, but the accounting and audit firms that move first won’t just keep up with the market—they’ll redefine it.
Narrow Window for Estate Planning Means UK HNWIs Should Act Soon
This is a pivotal year for UK estate planning and HNWIs should make deliberate decisions, and implement strategies to balance tax efficiency with personal and family needs without delay.
It’s Time to Abandon Digital Services Taxes for a Superior System
Growing criticism of digital services taxes should prompt countries to opt for a value-added tax framework in 2026 to better align tax policies for growth.
Building Executive Presence Is a Learnable Skill for Lawyers
It’s a myth that executive presence is an innate quality that can never be learned. And having this human element matters more than ever in a time where AI is taking on more legal research, drafting, and analysis.
These Hidden Legal Bets Shape Every Major Business Decision
Companies must make consequential decisions without knowing what the rules are or will be, and the legal pressures—dynamics affecting how businesses compete, invest, and plan forcing these kinds of bets—are pervasive.
Columnist Corner
Hawaii’s “green fee” for cruise ships brings parity to accommodations and should survive constitutional scrutiny if the state successfully links cruise cabins to hotel rooms, Andrew Leahey argues in his latest Technically Speaking column.
“Hawaii’s approach offers a blueprint for other coastal states to follow suit,” Andrew writes, adding that equally applied taxes on land-based and waterborne lodging would sidestep the legal minefield of targeting ships or charging for harbor access. Read More
News Roundup
US Mulling Taxing Digital Economy After Global Minimum Tax Pact
It’s time to step back and assess prior work undertaken at the OECD to tax the digital economy, a top US Treasury Department official said.
Treasury Commits to Completing List of Reg Projects This Year
The Treasury Department plans to put out all the projects on its list of regulatory priorities this fiscal year, an official said Thursday.
More States Expected to Decouple From Trump’s Tax-Cutting Agenda
Lawmakers in Delaware, Illinois, Michigan, Pennsylvania, and Rhode Island took on a task that most states ignored last year: passing legislation to separate from the tax-cutting features of President Donald Trump’s signature 2025 law.
Expired Tax Breaks Spur Corporate Push for Retroactive Fixes
The question is no longer whether a suite of tax breaks for businesses will expire, but for how long.
Tax Management International Journal
Latin America’s Digital Tax Revolution: Can Businesses Keep Up?
Latin American tax authorities are swiftly adapting policies to capture digital revenue, challenging businesses to keep pace with new compliance demands.
Tax Management Memorandum
Interest Limitation Rules Alter Naked Credit Determinations
The 2025 tax law’s interest expense limitation changes may require companies to reexamine deferred tax asset valuation allowance assessments with possible impacts to naked credits.
Estate Planners Navigate New Terrain with Creator Economy
Advising content creators requires specialized strategies to address unique priorities, assets, and income streams.
Career Moves
Gibson Dunn Adds Corporate Tax Attorney as Partner in Palo Alto
Rachel Kleinberg joined Gibson Dunn as a partner in its tax practice group in Palo Alto, Calif., the firm announced Monday.
WeirFoulds Promotes Michael Ding to Partner in Tax Law Group
Michael Ding was promoted to partner at WeirFoulds in the firm’s tax law group as of Jan. 1, the firm said Monday.
Akin Promotes Two Corporate Tax Attorneys to Partner in New York
Akin Gump has promoted New York tax attorneys Aaron Farovitch and Richard Swanson to its partnership, the firm announced Monday.
White & Case Taps Cyril Valentin as Global Tax Partner in Paris
Cyril Valentin joined White & Case as a partner and will lead the firm’s global tax practice in Paris, the firm announced Monday.
Davis Wright Tremaine Promotes Malik, Widmyer to Tax Partner
Shelly Malik and Matthew Widmyer have been promoted to partner in the business and tax group at Davis Wright Tremaine, the firm announced Monday.
Paul Hastings Adds Andrew Davis as Partner in New York Office
Andrew Davis joined Paul Hastings as a partner in its tax practice in New York, the firm announced Tuesday.
DLA Piper Adds Philipp Stanek as Partner in Its Vienna Office
Philipp Stanek joined DLA Piper as a partner in its tax practice in Vienna, the firm announced.
Vinson & Elkins Hires Vinay Prabhakar as Tax Partner in New York
Vinay Prabhakar joined Vinson & Elkins as a partner in its tax practice in New York, the firm announced Wednesday.
Asbury Gardner Taps SALT Expert Raykin as Partner in Georgia
Alla Raykin joined Asbury Gardner as a partner in its state and local tax practice, the firm announced.
Morrison Cohen Brings On Ex-Baltimore Mayor, Lewis Baach Partner
Solomon Shinerock and Stephanie Rawlings-Blake joined Morrison Cohen as a partner and of counsel, respectively, in its government strategies and controversies practice, the firm announced Wednesday.
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