The Law Is Just the Start: Navigating the OBBBA Transition
When a major tax bill finally passes through Congress, there is a common misconception that the hard work is complete. For business owners and financial leaders, however, that legislative milestone is merely the opening whistle of a complex new phase.
Recently, the U.S. Department of the Treasury and the Internal Revenue Service published their 2026 Priority Guidance Plan. While this document might look like standard bureaucratic paperwork to the untrained eye, for our team at Christiansen Accounting, it serves as an essential roadmap. It shows exactly where federal regulators plan to focus their attention over the coming year—and where California businesses can expect critical answers to surface.
This year’s plan carries exceptional weight. It centers heavily on translating the sweeping provisions of the One Big Beautiful Bill Act (OBBBA) into actionable rules, while simultaneously attempting to cut through regulatory red tape by eliminating outdated tax requirements.
Why Legislation is Just the Starting Line
Congress is responsible for drafting and passing tax statutes, but the legislative branch rarely addresses the granular, day-to-day questions that business owners face. Instead, a new law provides the broad architecture. It is up to the Treasury Department and the IRS to construct the rules that dictate how the law functions in real-world scenarios.
These administrative details come in the form of regulations, revenue procedures, and notices. This regulatory output ultimately defines how your business calculates its deductions, makes official elections, documents its claims, and structures its long-term tax strategies. Until these clarifications are released, businesses are left trying to interpret high-level statutory language with limited administrative guidance. This is why we monitor administrative updates just as closely as the legislative votes themselves.
Clarifying the One Big Beautiful Bill Act
The Treasury’s 2026 agenda leaves no room for doubt: the top priority is implementing the massive provisions of the One Big Beautiful Bill Act. Substantial federal resources are being directed toward writing regulations for several key provisions that many of our clients are watching closely. These priority areas include:
- Research and development (R&D) expensing rules
- Bonus depreciation adjustments
- Section 163(j) business interest limitation provisions
- Opportunity Zones guidelines
- Foreign tax credit revisions
- The establishment and rules for Trump Accounts
- Remittance-transfer excise tax provisions
- Various other technical statutory rules within the legislation
Because these administrative projects will directly shape how you claim deductions, track investments, and report financial data, the real-world utility of these tax incentives remains incomplete until the Treasury defines the compliance framework. In the meantime, business planning must remain agile and responsive to new updates.
The Push to Simplify Existing Rules
In addition to drafting new guidelines, the Treasury’s 2026 agenda highlights a parallel focus on deregulation. Alongside the implementation of the new law, federal officials are targeting unnecessary or outdated rules for modification or removal to ease the compliance burden on taxpayers.
Key deregulatory projects outlined in the guidance plan include:
- The systematic removal of redundant tax regulations
- The withdrawal of specific partnership-related party basis-shifting rules
- Simplifying capitalization procedures under Section 263A
- Raising specific information-reporting thresholds
- Other efforts designed to minimize administrative overhead
While a reduction in regulatory complexity is welcome news, it introduces a separate compliance challenge. As older regulations are dismantled or updated, prior administrative guidance may no longer be reliable. Relying on outdated internet resources, historical tax planning templates, or old advice can introduce unexpected risk during periods of transition.
A Major Leadership Transition at Treasury
Even with a clear 2026 agenda, a significant human resource change could alter the timeline and delivery of these critical rules. Shortly after the guidance plan was published, Ken Kies departed his key government positions.
While his name may not be a household word outside of the tax profession, his departure represents a massive shift within our industry. As the Assistant Secretary for Tax Policy, he headed the Treasury's Office of Tax Policy and held a major leadership role within the Office of Chief Counsel. These roles placed him squarely at the center of how federal tax policy is written, coordinated, and executed.
Whenever complex technical disputes required resolution or major regulations needed cross-agency alignment between the Treasury and the IRS, he was a pivotal figure in those negotiations. Replacing that level of deep institutional expertise and leadership capability is a slow process, and it occurs at a time when the government is trying to roll out highly complex legislation.
Anticipating Delays in Implementation
Although the core objectives of the 2026 Priority Guidance Plan are unlikely to change, leadership transitions frequently shift administrative timelines and resource allocation. Some anticipated regulations may be delayed, while other draft rules might undergo additional layers of review or policy reassessment before they are officially published.
For businesses awaiting clear answers on the OBBBA’s provisions, patience will be essential. Getting definitive guidance on these complex rules is simply going to take time as the agency stabilizes its leadership team.
The Multi-Stage Regulatory Process
It is also important to remember that tax guidance is rarely delivered as a single, finalized package. Instead, it is an iterative process. The Treasury typically begins by issuing preliminary notices, which are later developed into proposed regulations. These proposed rules are then opened to public comment, revised based on feedback, and ultimately published as final regulations‑often followed by subsequent technical corrections.
This slow evolution means that tax interpretations can change dramatically from the time a bill is signed to the time the final rules are locked in. This makes it critical to periodically review and update tax strategies that were formulated immediately after the law was passed.
The Risk of Outdated Tax Assumptions
Because the federal government is actively trying to streamline existing tax rules, many long-standing regulations may be declared obsolete, rewritten, or withdrawn in the coming months. A strategy that complied perfectly with guidance from a few years ago might no longer align with current regulatory standards.
This does not mean the initial strategy was flawed; it simply reflects the fluid nature of modern tax policy. Partnering with a proactive advisor ensures you recognize when yesterday’s rules no longer fit today’s legal reality.
Proactive Monitoring for Your Business
While most business owners naturally focus on the headlines surrounding new legislation, our role at Christiansen Accounting is to monitor the detailed administrative work that happens behind the scenes. How the IRS and Treasury interpret these new laws directly dictates how you document deductions, structure investments, and manage your overall compliance footprint.
Over the coming year, we will be tracking the steady release of notices, proposed regulations, and guidance updates concerning business deductions, international transactions, investment structures, and the unique tax benefits of the OBBBA. We will also monitor deregulatory shifts to ensure your tax planning remains accurate and optimized.
Navigating the Next Phase of Tax Reform Together
The enactment of the One Big Beautiful Bill Act was only the first step. The ongoing work of translating that legislation into concrete rules has now begun, but the recent departure of key Treasury leadership introduces real questions about how quickly those rules will materialize. As the regulatory process unfolds and older rules are phased out, tax planning strategies must remain highly flexible.
If you are planning a major corporate transaction, restructuring your business entity, or making significant new investments, relying on historic rules could expose you to unnecessary risk. Contact Christiansen Accounting today to discuss how these developing federal rules affect your specific tax position here in California. Let’s work together to ensure your business remains ahead of the curve.
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