The mega-reform, measure by measure
It was passed by Congress on August 4th, but it is not yet law. And it is upon publication, not before, that each deadline begins to run.
Analysis by topic
The Reconstruction Act is not just a single change: it is a package. It lowers the corporate tax rate, reintegrates the system, opens temporary windows to regularize capital and debts, and cuts the gift tax in half for high-net-worth families.
Frequently asked questions
Not yet. On August 4, 2026, Congress passed the Reconstruction Act, but for it to become law, the President must promulgate it and it must be published in the Official Gazette. Until that happens, none of its measures are in effect and no deadlines have begun to run.
Because it is not just a change, it is a package. The Reconstruction Act lowers the corporate tax, reintegrates the tax system, opens four temporary windows to regularize capital and debts, cuts the gift tax in half, and modifies the treatment of stock market capital gains, among other matters. The press dubbed it a "mega-reform" due to its scope: it is the most comprehensive tax package in over a decade.
This is the name given to the National Reconstruction and Economic and Social Development Bill (Bill 18.216-05), introduced to Congress on April 22, 2026. It combines permanent tax measures, such as the corporate tax cut, with temporary measures linked to financing reconstruction.
The reduction is gradual: 25.5% in 2027, 24% in 2028, and 23% from 2029 onwards. The 2026 tax year remains at 27%. In parallel, the 35% restitution is being eliminated, so the credit available to owners when withdrawing profits will rise to 70% in 2027, 80% in 2028, and 100% from 2029.
The window lasts 12 months, but it is counted from the first day of the second month after its publication in the Official Gazette, which has not yet occurred. Therefore, there is no closing date yet. What you should do now is the preliminary work: valuing assets and organizing your family structure, which is what takes weeks.
The Constitutional Court has already ruled: in August 2026, it partially accepted the challenges. It limited tax stability, which now applies only to large investment projects, and declared the compensation for annulled Environmental Qualification Resolutions unconstitutional; those provisions will not be included in the final text. The rest of the package (the rate reductions and the temporary windows for gifts, FUT, and repatriation) was not challenged and still stands.
Preparation. Almost all windows require preliminary work that takes weeks: valuing assets, organizing accounting records, and documenting the origin of offshore assets. Those who arrive prepared can act on day one; those who start from scratch once it is published will be cutting it close. This work is valuable regardless of when the law is published.
Every case has a different window. Yours begins with the publication of the law.
We work with you to prepare the structure, valuation, and timelines so you can act on day one, not weeks later. Let’s talk before the bill becomes law.
This content is for informational purposes only and does not constitute legal or tax advice. It is based on the text of the National Reconstruction and Economic and Social Development Act (Bill 18.216-05), passed by Congress on August 4, 2026, and reviewed by the Constitutional Court. The final text will be the version promulgated and published in the Official Gazette. Please consult on your specific case before making any decisions.