President Trump marked the Fourth of July with a White House signing celebration for his "One Big Beautiful Bill" (H.R. 1). The bill, which cleared the House and Senate last week on close votes, now moves to the implementation and regulation stage at the Department of the Treasury and Internal Revenue Service (IRS). 

Notices and other subregulatory guidance will soon start to flow from Treasury and the IRS Office of Chief Counsel, followed by Notices of Proposed Rulemakings and other moves toward formal regulations. One relevant factor is the paucity of legislative history behind H.R. 1. The Joint Committee on Taxation (JCT) did provide a bill description in connection with the House Committee on Ways and Means markup. The Senate Finance Committee, which wrote and revised major portions of the final language signed into law, did not hold a formal markup, meaning no bill description was issued for the initial Senate version, nor for the changes made right before final passage. We may be forced to wait two more years before JCT issues its Blue Book for the 119th Congress, describing all its enacted tax legislation. 

Another post-enactment exercise that starts now is the search for what got mis-worded, mis-cited, or otherwise went awry in the writing process. The speed at which the Senate-crafted version moved to the floor, and its last-minute rewrite and adoption as a substitute amendment, makes us suspect that the list of technical corrections to the final bill might be longer than usual. A detailed explanation of the technical corrections process can be found here. #TaxTake

In the News

Marc commented in Law360 Tax Authority on H.R. 1 being budget reconciliation bill is the defining federal tax policy of 2025. "There obviously hasn't been anything else passed and the legislative agenda is obviously all tied to this bill." 

Marc was also quoted in Bloomberg Tax on bipartisan tax priorities that have been left out of H.R. 1. "There is a question of kind of the fallout from this bruising reconciliation bill, and how quickly the parties turn to working on a bipartisan bill."

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