On Jul. 4, 2025, President Trump signed The One Big Beautiful Bill Act (OBBBA) into law as Public Law 119-21. Title XI of the law contains the tax provisions for the 2025–2026 federal budget.

The One Big Beautiful Bill Act, signed on Jul. 4, 2025, includes changes that apply to controlled foreign corporations and their US shareholders. Two of those changes affect whether a US taxpayer has a Form 5471 filing requirement and an income inclusion for a foreign corporation’s subpart F income or net Controlled Foreign Corporations (CFC) tested income—the new name for global intangible low-taxed income. The changes are effective for foreign corporation tax years beginning after Dec. 31, 2025. 

On Dec. 20, 2024, the Treasury Department and the IRS released proposed regulations (REG-116610-20) to update Circular 230, which governs practice before the IRS. These amendments, if finalized, would have a substantial impact on attorneys, CPAs, enrolled agents, and other tax professionals who practice before the IRS. Understanding these proposed amendments is essential for tax practitioners to prepare for potential changes ahead.

Many Americans faced overreaching tax changes with the Tax Cuts and Jobs Act of 2017. Taxpayers’ attention went to items like the Qualified Business Income Deduction, Net Operating Losses, and sweeping tax rate changes across the board. However, an often overlooked change was a revision to Section 174 and the introduction of a new definition for specified research or experimental (SRE) expenditures. This change was not slated to go into effect until the 2022 tax year, and once it arrived, it came with endless taxpayer questions and a lack of federal guidance on implementation.

In Loper Bright Enterprises et al. v. Raimundo, 544 F. Supp. 3d 82, 103-04 (2021), the U.S. Supreme Court overturned the Chevron doctrine, a policy of deferring court discretion to federal agency regulations. Chief Justice Roberts authored the majority (6-3) opinion.