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Tax Strategy: The difficult road to tax legislation in 2025

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Congress has started on the process of enacting major tax legislation in 2025. While both chambers of Congress and the Trump administration seem to want major tax legislation this year, and most expect them to somehow be able to achieve it, it looks like it is going to be a very difficult process.

As is often done with tax legislation by the party in the majority, to avoid the filibuster rules in the Senate requiring a 60-vote margin, the Republicans propose to pass the legislation under the budget reconciliation rules, requiring only a simple majority vote. Usually, the rules only permit one budget reconciliation bill per year; however, since no budget reconciliation bill was utilized in 2024, the rules permit two budget reconciliation bills this year.

At press time, the House was working on one large bill that includes taxes, border issues, and anything else related to revenue. The rules forbid inclusion of any provisions not germane to revenue. The Senate, however, is currently pursuing two budget reconciliation bills, with the first including everything except taxes, and taxes postponed to the second bill later in the year.

Before starting on the tax legislation itself, the House and Senate are required to agree on a budget framework, specifying how much in tax cuts and spending cuts may be included in the legislation.

A close up of the capital building with an American flag

The House, by a bare majority vote of 217-215, approved a budget resolution specifying $4.5 trillion in tax cuts and $2 trillion in spending cuts. The House resolution also assigned some allocations of spending cuts to specific committees, including an allocation of $880 billion to the House Energy and Commerce Committee, which is responsible for Medicaid.

The Senate has approved a budget number for its first budget reconciliation bill; however, it has not yet approved a budget number for the second reconciliation bill on tax matters. The House and Senate must agree on identical budget reconciliation numbers before proceeding to the legislative committees. It has been estimated that achieving this budget agreement alone could take into the mid-April time frame, and those estimates are usually optimistic.

Budget reconciliation also comes with some additional restrictions. In addition to all provisions being required to relate to revenue, budget reconciliation also requires that there be no projection of negative revenue impact beyond 10 years. This results in budget reconciliation bills often including temporary provisions, phase-ins and phase-outs to try to stay within the approved budget numbers.

The Tax Cuts and Jobs Act

The primary focus of the tax legislation this year is extending the individual provisions of the Tax Cuts and Jobs Act that expire at the end of 2025, a result of the TCJA itself having been passed under budget reconciliation with the budget number and 10-year restrictions.

There are also several business provisions that started to phase down a couple of years ago that the Republicans would also like to restore retroactively. Extending all these provisions permanently is estimated to cost over $4 trillion. It is estimated that a seven-year extension, as discussed in the House, would cost $3.7 trillion.

One key difference between the House and Senate is whether to just extend these provisions for some additional years or make them permanent. The Senate position currently is that they should be permanent, while the House appears willing to extend them for a shorter period in order to include some additional tax breaks. Both the House and Senate appear willing to utilize a current policy baseline in determining the extent to which tax provisions need to be offset to come within the budget reconciliation limitations.

Under the current policy baseline, merely extending provisions of the Tax Code already in effect does not require revenue offsets to avoid being counted in the budget restriction numbers. Congress has more commonly used a current law baseline, which would require extensions to be offset. This opens up $4 trillion for other tax cuts proposals; however, it still adds $4 trillion to any projected deficits. While it might work for budget reconciliation, it is likely to raise opposition from deficit hawks in Congress about its use greatly contributing to the deficit.

Other tax breaks

The legislation is also likely to consider additional tax breaks. In addition to the expiring TCJA provisions, additional expiring provisions likely to get consideration for extension include the Work Opportunity Tax Credit and the New Markets Tax Credit.

President Trump has also proposed several additional tax breaks: eliminating the tax on Social Security benefits, eliminating the tax on tips, eliminating the tax on overtime, exempting Americans living abroad from income tax, and reducing the corporate tax rate to 15% for domestic manufacturers and to 18% or 20% for other corporations.

Trump has also seemed open to modifying or eliminating the $10,000 state and local tax deduction limit included in the Tax Cuts and Jobs Act, which might also be necessary to gain the support of Republicans in Congress from high-tax states, although there is also a proposal to include eliminating the pass-through entity work-around for the SALT deduction.

Republicans have also generally supported repeal of the estate tax and repeal of the corporate alternative minimum tax.

Revenue raisers and spending cuts

President Trump has also mentioned some possible revenue raisers, which might provide a revenue offset for some of these tax cuts:

  • Taxing carried interests at ordinary income rates;
  • Increasing the tax on private university endowments;
  • Reducing deductions available to sports team owners;
  • Repealing or reducing the mortgage interest deduction;
  • Repealing some or all of the green energy tax credits included in the Inflation Reduction Act;
  • Ending the Employee Retention Credit;
  • Repealing the nonprofit status of hospitals;
  • Repealing the exclusion for municipal bond interest; and,
  • Pulling back some IRS enforcement funding.

Trump also views his tariff proposals as providing additional revenue offsets.
The spending cut provisions in the budget reconciliation will also require difficult decisions with respect to determining who will bear the burden of those cuts. We have already seen the disarray created by the efforts of the Department of Government Efficiency to reduce the federal workforce.

Narrow Republican margins

Not only are there differences between the Republicans in the House and Republicans in the Senate, there are also differences among the Republicans in each body.

The narrow Republican majorities in both the House and Senate means that passage requires attracting the votes of almost every Republican member. This has proved especially difficult for the House, as evidenced by the budget number approval passing by only a two-vote margin, and that was only achieved by getting members to put off their concerns until they could be addressed during the legislation drafting process.

Postponing those issues until later just adds more difficulty in crafting legislation in a way that will retain those votes. Some of those issues include the SALT deduction limit, the permanency of the Tax Cuts and Jobs Act extension, potential reductions in Medicaid funding, and deficit concerns.

Summary

While the odds of major tax legislation this year still look good, it is likely to be a very difficult process that drags on through much of the year. It appears that either some of the proposed tax cuts will have to be passed on or put into effect for only a limited period, that deficits will be significantly increased, or that budget gimmicks such as use of the current policy baseline or taking tariffs into account will be used to try to claim compliance with the budget reconciliation numbers.

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Accounting

IRS offers penalty relief for micro-captive transactions

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The Internal Revenue Service issued a notice Friday giving some breathing room to participants and advisors involved with micro-captive insurance companies.

In January, the IRS issued final regulations designating micro-captive transactions as “listed transactions” and “transactions of interest,” akin to tax shelters. The IRS had proposed the regulations in 2023 but needed to be careful to comply with the Administrative Procedure Act to allow for a comment period and hearing after a 2021 ruling by the Supreme Court in favor of a micro-captive company called CIC Services because the IRS hadn’t followed those procedures back in 2016 when designating micro-captives as transactions of interest. However, the micro-captive insurance industry has asked for more time to comply with the new reporting and disclosure requirements, and one group known as the 831(b) Institute announced earlier this week it had sent a letter to the IRS’s acting commissioner requesting an extension.

On Friday, the IRS issued Notice 2025-24, which provides relief from penalties under Section 6707A(a) and 6707(a) of the Tax Code for participants in and material advisors to micro-captive reportable transactions for disclosure statements required to be filed with the Office of Tax Shelter Analysis. However, the relief applies only if the required disclosure statements are filed with that office by July 31, 2025. 

In the notice, the IRS acknowledged that stakeholders had raised concerns regarding the ability of micro-captive reportable transaction participants to comply in a timely way with their initial filing obligations with respect to “Later Identified Micro-captive Listed Transactions” and “Later Identified Microcaptive Transactions of Interest.”

In light of the potential challenges associated with preparing disclosure statements during tax season and in the interest of sound tax administration, the IRS said it would waive the penalties under Section 6707A(a) with respect to Later Identified Micro-captive Listed Transaction and Later Identified Microcaptive Transaction of Interest disclosure statements completed in accordance with Section 1.6011-4(d) and the instructions for Form 8886, Reportable Transaction Disclosure Statement, if the participant files the required disclosure statement with OTSA by July 31, 2025.   

The relief is limited to Later Identified Micro-captive Listed Transactions and Later Identified Micro-captive Transactions of Interest. However, the notice does not provide relief from penalties under Section 6707A(a) for participants required to file a copy of their disclosure statements with OTSA at the same time the participant first files a disclosure statement by attaching it to the participant’s tax return.  

Taxpayers who are concerned about meeting the due date for these disclosure statements can ask for an extension of the due date for their tax return to obtain additional time to file such disclosure statements. The disclosures required from participants in micro-captive listed transactions and transactions of interest on or after July 31, 2025, remain due as otherwise set forth in the regulations. 

There’s also a waiver for the material advisor penalty for similar reasons. “In light of potential challenges associated with preparing disclosure statements during tax return filing season and in the interest of sound tax administration, the IRS will waive penalties under section 6707(a) with 5 respect to Later Identified Micro-captive Listed Transaction and Later Identified Microcaptive Transaction of Interest disclosure statements completed in accordance with § 301.6111-3(d) and the instructions to Form 8918, Material Advisor Disclosure Statement, if the material advisor files the required disclosure statement with OTSA by July 31, 2025,” said the notice. “Disclosures required from material advisors with respect to Micro-captive Listed Transactions and Micro-captive Transactions of Interest on or after July 31, 2025, remain due as otherwise set forth in § 301.6111-3(e).  This notice does not modify any list maintenance and furnishment obligations of material advisors as set forth in section 6112 and § 301.6112-1. “

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Accounting

Transforming accounting firms through connected leadership

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In my work with accounting firms, I’ve lost count of how many times I’ve heard partners say some version of: “We’re paying top dollar. Why are people still leaving?” One conversation particularly sticks with me — a managing partner genuinely baffled by rising turnover despite offering excellent compensation packages.

What I often discover isn’t surprising: Many firms have mastered technical excellence and client service while leadership runs on autopilot. They focus almost exclusively on metrics and deadlines, forgetting the human element. No wonder talented professionals walk out the door seeking workplaces where they’re valued for more than just their billable hours.

We’re facing a significant talent challenge in our profession. From 2020 through 2022, approximately 300,000 U.S. accountants and auditors have left their jobs — a dramatic shift that should concern all of us. While retiring baby boomers account for some of this exodus, we also see professionals in their prime years leaving the profession.

(Read more:Connected Leaders: Cultivating deeper bonds for team success“)

The timing couldn’t be worse. The Bureau of Labor Statistics projects about 136,400 accounting and auditing job openings annually through 2031, creating a significant gap between talent supply and demand. This challenge requires more than recruitment tactics or compensation increases — it demands a fundamental shift in how we lead.

The disconnection crisis

Traditional accounting leadership has often prioritized technical excellence and client service at the expense of human connection. We’ve built cultures where being constantly available somehow equals commitment, boundaries are treated as limitations rather than assets, and professional development means technical improvement instead of leadership growth.

Technology has both connected and disconnected us. I’ve worked with firms where team members haven’t had a meaningful conversation with their managers in months despite being on Zoom calls together every day. This disconnect leads to declining engagement and stalled innovation, and makes retaining talented professionals increasingly difficult.

Connected leadership isn’t complicated — it’s about creating real relationships through intentional practices that build trust. It’s the opposite of the “manage by spreadsheet” approach that’s all too common in our profession.

I love thinking about connected leadership like conducting an orchestra. Great conductors don’t just keep time — they understand what makes each musician unique, create space for individual expression within the group, and know when certain sections should shine while others provide support. Most importantly, they get that beautiful music comes from relationships, not just technical precision.

This approach sits at the heart of what I teach through The B³ Method — Business + Balance = Bliss. When leaders create environments where team members feel genuinely seen and valued, magic happens — both in personal fulfillment and on the bottom line.

orchestra conductor

Alenavlad – stock.adobe.com

The business case for connection

Before dismissing this as too “soft” for our numbers-driven profession, consider the data. According to Gallup’s 2024 State of the Global Workplace report, low employee engagement costs the global economy $8.9 trillion annually — an extraordinary sum that affects businesses of all sizes.

Organizations with high engagement see 21% higher profitability and significantly lower turnover. What accounting leaders really need to understand is that managers account for 70% of the variance in team engagement. When managers themselves are engaged, employees are twice as likely to be engaged too. These positive shifts translate to better retention, stronger client relationships and improved profitability.

Beyond retention, connected leadership directly impacts client relationships and innovation. When team members feel psychologically safe, they’re more likely to raise concerns, suggest improvements, and deliver exceptional client service.

Becoming a connected leader

You don’t need to overhaul your entire firm to start seeing results. Try these practical approaches:

  1. Take a beat. Before jumping into solutions or directives, pause to really listen. Some of my most successful clients start meetings with “connection before content” — spending just a few minutes establishing human connection before diving into the agenda. I recently had an attendee of my Connected Leadership workshop tell me: “Taking just two minutes to meditate can remarkably reset the nervous system, providing a quick and effective way to find calm and focus during a busy workday.”
  2. Create boundary rituals. Work-life harmony isn’t about perfect balance — it’s about intentional integration. Help your team establish clear boundaries that actually enhance client service, like “no-meeting Fridays” or dedicated deep work blocks. One partner told me their key takeaway was “to take care of myself to be better in all aspects of life!”
  3. Measure what matters. Beyond billable hours and realization rates, assess team connections through regular check-ins focused on engagement and belonging. Another workshop participant noted that, as a leader, they must take “100% responsibility for my own actions and outcomes.” What gets measured gets managed — so measure the human element, too.
  4. Get comfortable with vulnerability. Share appropriate challenges and lessons learned, showing that vulnerability is a strength. Poignant feedback from my last workshop stated: “For the managing partners and leaders of the organization to put out there for us their vulnerabilities, past struggles, and pain is a testament to their humanity and endurance, and that is a powerful takeaway.”

The future of accounting leadership

Implementing connected leadership will likely face resistance, particularly in traditional accounting environments. This approach can initially be misperceived as “soft” or less important than technical skills. However, the firms that successfully navigate this transition recognize that connected leadership isn’t separate from business success — it’s foundational to it.

When faced with resistance, start small with measurable experiments. Document outcomes, adjust approaches and gradually expand successful practices. Focus on the business case rather than just the human case, though both are equally important.

As our profession navigates unprecedented talent challenges, we need to evolve how we lead. The firms that will thrive won’t just be those with the best technical expertise — they’ll be the ones where leaders prioritize connection alongside excellence.

I challenge you: Are you leading in a way that creates meaningful relationships, or are you perpetuating a culture where people feel like just another billable resource? Your answer might determine whether your firm struggles to keep talent or becomes a magnet for professionals seeking both success and fulfillment.

In an orchestra, the most powerful moments often come not from individual instruments playing louder, but from all sections playing in harmony. The same is true for our teams.

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Accounting

Ohio welcomes out-of-state CPAs after new law

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Ohio’s new law providing an alternative path to a CPA license has taken effect after 90 days and the Ohio Society of CPAs is pointing out another provision of the law, enabling out-of-state CPAs to practice in the Buckeye State.

Ohio Governor Mike DeWine signed House Bill 238 in January, enabling qualified CPAs from other states to work in Ohio, The OSCPA noted that other states are working to adopt similar language to Ohio. 

“Automatic interstate mobility essentially works like a driver’s license,” said OSCPA president and CEO Laura Hay in a statement Thursday. “You can drive through our state without an Ohio license, but you still must follow our laws and if you don’t, you’re penalized. The same applies here – a licensed CPA in good standing can now practice here but must adhere to our strict professional standards.”

Four other states — Alabama, Nebraska, North Carolina and Nevada — currently function under this model. That means a CPA with a certificate in good standing issued by any other state is recognized and allowed practice privileges in those four states as well as Ohio. A number of states like Ohio are also taking steps to provide alternative pathways to CPA licensure aside from the traditional 150 credit hours. In addition, approximately half of all jurisdictions have indicated they are shifting to automatic mobility to ensure that CPAs from all states will have practice privileges and be under the jurisdiction of the state’s board of accountancy.  

“The realities of globalization and virtualization place greater importance on the individual’s qualifications, rather than their place of licensure,” Hay stated. “And the more states we have that accept this model, the more successful we will all be in addressing the national CPA shortage.”

State CPA societies as well as the American Institute of CPAs and the National Association of State Boards of Accountancy have been working on ways to make the CPA license more accessible to expand the pipeline of young accountants coming into the profession and relieve the shortage. 

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