IRS and Treasury officials, speaking at the Federal Bar Association Tax Law Conference March 5, detailed an ambitious schedule of forthcoming guidance for the remainder of the year, with a primary focus on implementing the One Big Beautiful Bill (OBBB) as quickly as possible while reflecting stakeholder feedback.
Forthcoming Domestic Guidance
On the domestic front, officials confirmed that a number of high-priority projects are moving toward proposed or final regulations. According to Julie Bolton, associate chief counsel for Income Tax & Accounting, and Philip Lindenmuth, executive counsel to the Chief Counsel, practitioners can expect a comprehensive package of regulations for the Corporate Alternative Minimum Tax (CAMT) around the end of the year.
This package will incorporate interim guidance from previous notices and address public comments on compliance burdens and fair value issues. For research and development expenditures under IRC § 174, teams are actively working through comments on software development and contract research definitions.
Officials teased the release of proposed regulations for the new IRA-like “Trump accounts” for minors, which were issued March 6, as promised. Lindenmuth stated that officials hope to issue additional guidance on employer contributions before the accounts go live on July 4.
In other areas, final regulations on the definition of tip-eligible occupations are expected in the near future following the issuance of penalty relief for 2025 in Notice 2025-62 and transition relief for individuals in Notice 2025-69. In light of the numerous comments received on Notice 2025-70, a large, cross-divisional team is now developing more detailed regulations for Scholarship Granting Organizations.
While guidance on Health Savings Accounts in Notice 2026-5 is considered largely self-executing, the IRS is continuing to monitor for questions that may require further clarification. Finally, dedicated teams continue to work on guidance to implement the retirement-related provisions of the SECURE 2.0 Act, which remains a main priority.
International Rules on the Horizon
James Wang, international tax counsel at Treasury, outlined a packed agenda for international tax guidance, which the department is triaging based on statutory effective dates. For provisions effective in 2025, Treasury plans to issue proposed regulations by mid-year and finalize them by the end of the year. For provisions effective in 2026, proposed regulations are targeted for release by the middle of the year or sometime in the third quarter, with final rules also expected by year-end.
Wang noted that Treasury is seeking significant taxpayer feedback on how to allocate a controlled foreign corporation’s income, particularly on whether to use a pro rata approach or a “closing of the books” method for extraordinary transactions. Proposed regulations implementing prior notice guidance on the IRC § 898 deferral repeal are also planned for mid-year, with final regulations by the end of the year.
Regarding IRC § 892 for sovereign wealth funds, officials are reviewing comments on proposed regulations concerning commercial activity and the “effective control” standard. Wang stated that all options are on the table to avoid disrupting established market practices, including making changes, providing transition relief, or withdrawing parts of the proposal.
Treasury is also analyzing the statutory change under IRC § 250 for the foreign-derived intangible income/global intangible low-tax income deduction, which changed from “deductions” to “expenses and deductions,” to determine legislative intent but has not yet settled on an approach.
Early Public Feedback
Officials emphasized that their current rulemaking strategy is designed to be responsive to taxpayer needs by moving quickly while gathering public input. Wang explained that the heavy use of notices for new provisions serves a dual purpose: to provide immediate clarity to taxpayers and to solicit early feedback from the tax community.
This multi-step approach — issuing a notice to float ideas and gather comments before moving to proposed and final regulations — allows the government to refine its approach before rules are set in stone. “We really think that there’s real benefit to taxpayer community engagement and feedback, and as much of it as we can get,” Wang said.
This focus is also reflected in the 2025-2026 Priority Guidance Plan, which Bolton confirmed is heavily concentrated on implementing the OBBB. While other projects are still being worked on, she noted they are proceeding at a “slower pace” to allow the agency to focus on the most pressing legislative mandates.
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