Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to provide updates you need to know for your business.
Tax developments
One not-so-big summary of the compensation and benefits law changes in the One Big Beautiful Bill Act
The One Big Beautiful Bill Act, signed into law on July 4, 2025, contains a number of changes that may impact US employers and benefit plan sponsors.
- The telehealth exception for high-deductible health plans was made permanent and retroactive to December 31, 2024.
- The Act makes other changes that could impact employers, including changes to Sections 162(m) and 4960 of the Code, which relate to “excess” compensation paid to executives, permitting employer contributions to newly-established Trump Accounts, and increasing the DCAP limit.
- The Act includes a limited individual deduction for “qualified tips” and “qualified overtime.”
Read our full alert here.
Loper Bright’s continued impact: Tax Court holds final partnership adjustment untimely, invalidates conflicting regulation
On July 2, 2025, the Tax Court issued a unanimous reviewed opinion in JM Assets, LP v. Commissioner, holding that the IRS did not timely issue a final partnership adjustment (FPA) under the Bipartisan Budget Act of 2015 (BBA). Citing the plain text of section 6235, the Tax Court held that an FPA must be issued within 270 days after the date everything required for a complete modification request under section 6225(c) has been submitted.
The opinion exemplifies the Tax Court’s role in interpreting the procedural nuances of the centralized partnership audit regime enacted as part of the BBA and its approach to statutory and regulatory interpretation following the Supreme Court’s decision in Loper Bright and the Tax Court’s decision in Varian Med. Sys., Inc. v. Commissioner.
Read our full alert here.
Stay informed on business tax reform
We’re excited to share the newly updated Tax Reform Law minisite, your resource for timely updates on Congressional activity, administrative guidance, and key developments shaping business tax.
Be sure to explore our Resource Library, a curated archive of legislative materials and past administrative guidance to help you track and understand reform over time.
Explore the minisite by visiting the following link: http://www.taxreformlaw.com
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