Last week, a number of top tax policy officials addressed the Tax Council Policy Institute's (TCPI) annual conference in Washington, DC, with updates on the legislative and regulatory agenda for the remainder of the year. Here are the highlights.

Assistant Treasury Secretary for Tax Policy Ken Kies opened the conference with remarks focused on implementing the One Big Beautiful Bill Act (OBBBA), executing a smooth filing season this year and next, and the latest settlement offer for taxpayers in disputes with the Internal Revenue Service (IRS) over donations of conservation easements. He predicted the new settlement offer, including more flexible payment terms, will settle at least half of the current caseload. He also discussed a continued focus on captive insurance arrangements and work underway at Treasury involving the economic substance doctrine.
 
Kevin Salinger, Deputy Assistant Secretary at Treasury, added some details to the regulatory agenda. He said to expect a reproposed regulatory package on the corporate alternative minimum tax (CAMT) in February 2027 that will incorporate the five previous guidance notices issued. The timing for release, he said, is aimed at avoiding year-end financial statement reporting issues for calendar year taxpayers. He said to expect new rules on foreign entities of concern (FEOCs) by the end of the year, and continuing work on guidance with respect to non-profit executive compensation, business and entertainment deductions, the section 199A deduction for passthrough business income, and the qualified small business stock gain exclusion.
 
House Committee on Ways and Means Chairman Jason Smith (R-MO) told the conference he had just left a closed-door meeting on the taxation of digital assets, noting the opportunity for bipartisan action on the issue. He set out his view that all legislation considered this year by his committee must be bipartisan. "Everything that we move forward on at Ways and Means needs to be bipartisan, because I want to legislate," he said. "I don't want to just, like, pass things just to pass things. I want them to become law."
 
Chairman Smith was also quick to note and praise his collaborative work with Senator Ron Wyden (D-OR), the Ranking Member of the Senate Committee on Finance. Also speaking at the conference, Senator Wyden said he would focus on vigorous oversight of the Trump administration if Democrats take control of the Senate in November. He also expressed some optimism for bipartisan action this year on IRS administrative reforms and perhaps some post-election action to address the expired work opportunity tax credit (WOTC), retirement savings, and tax treaty-like treatment for U.S.-Taiwan commerce. Finally, he outlined plans for legislation to reinstate the green energy tax provisions that were repealed by the OBBBA.
 
On the multilateral front, Manal Corwin, Organisaton for Economic Cooperation and Development (OECD) Director of the Centre for Tax Policy and Administration, and Rebecca Burch, Deputy Assistant Treasury Secretary for International Tax Affairs, discussed successes and future challenges related to the international tax work of the OECD. Corwin previewed today's release of new OECD Pillar 2 guidance with penalty relief and other guidance for multinational companies to address practical difficulties attendant to the looming filing deadlines for 2024 GloBE Information Returns (GIRs). #TaxTake

Upcoming Speaking Engagements 

Marc, Sam Lapin, and Lisandra Ortiz will speak at the Federal Bar Association (FBA) Insurance Tax Seminar on May 28-29
 

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