Jorge Castro, former Counselor to the IRS Commissioner and congressional tax counsel, discussed the need for IRS guidance following the enactment of H.R. 1, the One Big Beautiful Bill Act, which was signed into law on July 4. Castro said taxpayers will need the IRS provide details on a variety of issues to implement H.R. 1. He emphasized the importance of clarity around the retroactive application of immediate expensing for research and experimental (R&E) costs, particularly for small businesses. "Congress' intent is to make sure that small businesses can claim retroactive relief pretty soon," he noted, urging the IRS to define the process for amended returns and retroactive elections. He highlighted the uncertainty facing taxpayers under the statutory text for H.R. 1, "There's a question mark of whether or not they must file an amended return; can they make the retroactive election to their original return," according to Castro. "The small business community obviously is going to care about the R&E provisions a lot. And I think they're [] waiting for guidance on how to move forward," he said, pointing to the IRS Office of Chief Counsel and the Department of the Treasury's Office of Tax Policy as key players in providing regulatory guidance.