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
Big Beautiful Bill 2.0: Senate’s version would permanently extend TCJA provisions and close interest planning
On June 16, 2025, the Senate Finance Committee released proposed text for tax provisions to be included in the Senate’s version of the One Big Beautiful Bill Act (OBBB). Our prior alert addresses the House version of the bill. The Senate proposal would permanently extend three key business-favorable tax provisions from the 2017 Tax Cuts and Jobs Act (TCJA) (compared to the five-year extensions provided in the House-passed bill). However, the Senate proposal would also close certain planning related to capitalized interest expense under the base erosion and anti-abuse tax (BEAT) and section 163(j). The proposed text will have to be approved by the full Senate and then return to the House for approval before it could become law. Although the text will likely undergo further changes during that process, the Finance Committee’s text is a positive sign that the final bill will include these three business-favorable provisions.
Read our full alert here.
Notice 2025-33 extends Form 1099-DA reporting relief
On June 12, 2025, the IRS released Notice 2025-33, which expanded transitional relief for reporting sales of certain digital assets on Form 1099-DA. While Treasury Regulations promulgated under section 6045 require reporting of certain digital asset sales occurring on or after January 1, 2025, Notice 2024-56 provided that the IRS would not impose penalties under sections 6721 and 6722 on brokers that filed to file information reports and furnish payee statements with respect to sales of digital assets effected during calendar year 2025, so long as the brokers made good faith efforts to file accurate and timely Forms 1099-DA and furnish accurate and timely payee statements. Notice 2025-33 extends the relief granted under Notice 2024-56 to sales effected during calendar year 2026.
Recent Eversheds Sutherland Tax insights
First-tier Tribunal considers the trading test for Entrepreneurs’ Relief (now Business Asset Disposal Relief)
Protecting Tax-Exempt Status: Practical Steps for Universities Amid Heightened Scrutiny
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