OBBBA Tax Preparer Practice Guide 2026: One Big Beautiful Budget Act

The One Big Beautiful Budget Act (OBBBA), enacted in late 2025, is the most significant revision to the Internal Revenue Code since the Tax Cuts and Jobs Act of 2017. For professional tax preparers, it is not a single event but a continuing implementation challenge: statutory text was enacted, but IRS guidance, updated forms, and software recognition of new provisions are arriving on a rolling schedule. The practitioners who serve their clients well in this environment are not the ones who wait for everything to be settled before acting. They are the ones who know which provisions are clear, which are pending, and how to document the uncertainty for both client files and their own professional protection.

This guide is written for PTIN holders, AFSP participants, enrolled agents, CPAs, and tax attorneys who need a practice-organized summary of OBBBA provisions, not a law review article and not a news headline. The structure follows the workflow of preparing a return and representing a client: individual return changes, credit and due diligence implications, pass-through and QBI provisions, payroll, collection enforcement changes, preparer-specific provisions, and form implications. Each section carries an explicit implementation hedge because the OBBBA was recently enacted and implementing regulations may be pending at the time you are reading this.

All OBBBA provisions described in this guide should be verified at IRS.gov before relying on them in client engagements. IRS procedures, form versions, regulatory guidance, and statutory interpretations are subject to change. This guide is informational and does not constitute legal or tax advice.

Section 1: OBBBA Overview -- What It Is and Why Practitioners Need a Practice-Organized Summary

As of June 2026, verify current law and IRS implementing guidance at IRS.gov; the OBBBA was recently enacted and implementing regulations may be pending or subject to change. The following overview reflects publicly available information as of June 8, 2026.

The One Big Beautiful Budget Act was signed into law in late 2025 following passage through reconciliation procedures. It extended or modified numerous provisions from the Tax Cuts and Jobs Act of 2017 that were scheduled to expire or sunset, while also enacting new provisions affecting individual income taxation, business taxation, collection and enforcement, and the preparer oversight framework. The Act's popular name is an artifact of the legislative process; its formal name, structure, and effective dates should be confirmed at IRS.gov.

Why a practice-organized summary matters

Practitioners do not encounter OBBBA provisions organized by legislative section. They encounter them organized by return type, client situation, and workflow step. A preparer working a Form 1040 with EITC needs to know whether the OBBBA changed EITC eligibility rules before completing Form 8867, not whether the relevant amendment is in Title II or Title IV of the Act. This guide is organized the way practitioners use the tax law: by the return workflow and the collection resolution sequence, with OBBBA changes keyed to the places where they appear.

The guide covers eleven areas. Because implementing regulations are pending on some provisions, the coverage depth varies: areas where statutory text is clear and IRS guidance has been issued receive full treatment; areas where guidance is pending are flagged with verification requirements. The year-end planning checklist in Section 9 and the regulatory implementation status section in Section 10 are the two most date-sensitive parts of this guide and should be treated as current only through June 2026.

Effective dates

OBBBA provisions have varying effective dates. Some apply to tax years beginning after December 31, 2025 (first TY2026 returns). Others apply to tax years beginning after December 31, 2026 or later. Still others were retroactive to prior years. The effective date for every OBBBA provision you plan to apply must be confirmed at IRS.gov. Misapplying an effective date is an error that can generate both accuracy-related penalties for the client and preparer penalties under IRC 6694. Implementing regulations may be pending; verify at IRS.gov.

Section 2: Individual Return Changes -- SALT, Standard Deduction, and AMT

As of June 2026, verify current law and IRS implementing guidance at IRS.gov; the OBBBA was recently enacted and implementing regulations may be pending. All figures in this section must be confirmed at IRS.gov before use in client returns.

SALT cap modifications

The TCJA capped the state and local tax deduction (SALT) under IRC 164(b)(6) at $10,000 per year ($5,000 for married filing separately). The OBBBA modified this cap for TY2026 and potentially later years. Verify the current OBBBA SALT cap figure, any phase-in or phase-out provisions, and any income-based limitations at IRS.gov before applying the SALT deduction on TY2026 returns. The OBBBA SALT modifications may be among the provisions for which implementing regulations were pending as of this guide's publication date; confirm IRS guidance has been issued for the specific provision you are applying.

Practitioners with high-SALT-exposure clients (primarily taxpayers in New York, New Jersey, California, and Illinois) should flag these returns for additional research before filing. The SALT cap is one of the highest-stakes OBBBA provisions for individual return practice because the prior-law limitation was a significant planning constraint, and any OBBBA expansion has substantial dollar impact on affected returns.

Standard deduction

The TCJA roughly doubled the standard deduction through 2025. The OBBBA enacted changes to the standard deduction amounts for TY2026. Verify the TY2026 standard deduction amounts at IRS.gov before filing. These amounts are also subject to annual inflation adjustment, so the OBBBA-enacted figure and the inflation-adjusted TY2026 amount may differ; confirm the current figures in IRS Revenue Procedure or Publication 501 for TY2026 before use. Implementing regulations may be pending; verify at IRS.gov.

Alternative Minimum Tax

The TCJA substantially raised the AMT exemption amounts and phase-out thresholds, dramatically reducing the number of individual taxpayers subject to AMT through 2025. The OBBBA enacted provisions affecting the AMT exemption amounts and phase-out thresholds for TY2026 and beyond. Verify the current TY2026 AMT exemption amounts and phase-out thresholds at IRS.gov; these are also subject to inflation adjustment. Practitioners preparing returns for higher-income clients should not assume TCJA AMT relief parameters continue automatically into TY2026 without confirming the OBBBA-modified figures. Implementing regulations may be pending; verify at IRS.gov.

Tax rate brackets

The TCJA modified individual income tax rates and brackets through 2025. Whether the OBBBA extended, modified, or replaced those rate structures for TY2026 must be verified at IRS.gov. Tax software vendors will update their bracket tables; practitioners should confirm their software's TY2026 bracket tables reflect the OBBBA rates before relying on software calculations. Implementing regulations may be pending; verify at IRS.gov.

Section 3: EITC, CTC, and Dependent Credit Changes -- Form 8867 Due Diligence Implications

As of June 2026, verify current law and IRS implementing guidance at IRS.gov; the OBBBA was recently enacted and implementing regulations may be pending. Any OBBBA modification to credit eligibility rules directly changes Form 8867 compliance requirements.

EITC modifications

The earned income tax credit (EITC) is among the return lines most heavily scrutinized by IRS automated examination selection. The OBBBA may have modified EITC income thresholds, credit amounts, age limits for childless EITC, or the definition of qualifying child. Each of these elements directly affects the questions on Form 8867 and the knowledge standard a practitioner must meet. Verify OBBBA EITC changes at IRS.gov before preparing TY2026 returns claiming EITC. If the OBBBA modified any element of EITC eligibility, the corresponding Form 8867 questions and required documentation may have changed; confirm updated Form 8867 instructions at IRS.gov. Implementing regulations may be pending; verify at IRS.gov.

The IRC 6695(g) due diligence penalty for EITC is $650 per failure (2026 inflation-adjusted figure; verify at IRS.gov). This penalty applies whether the failure is in the completion of Form 8867 or in the underlying knowledge standard, regardless of how EITC eligibility rules may have changed under the OBBBA. Practitioners should review their due diligence checklists and client interview procedures against updated TY2026 EITC rules before the filing season opens. See the EITC due diligence and Form 8867 guide for the full due diligence compliance framework.

Child Tax Credit and Additional Child Tax Credit

The TCJA modified the CTC amount, refundability, and income phase-out thresholds through 2025. The OBBBA enacted changes affecting the TY2026 CTC framework. Verify the OBBBA CTC amount, the refundable portion (ACTC), the income phase-in and phase-out thresholds, and the age and qualifying child definitions at IRS.gov before preparing TY2026 returns. The Form 8812 computation and the Form 8867 due diligence questions for CTC are both affected by any OBBBA changes; confirm updated instructions before filing. Implementing regulations may be pending; verify at IRS.gov.

American Opportunity Tax Credit (AOTC)

Verify whether the OBBBA enacted any changes to AOTC eligibility rules, income thresholds, or credit amounts at IRS.gov. AOTC is one of the four credits covered by the Form 8867 due diligence requirement under IRC 6695(g). Any OBBBA modification to AOTC eligibility rules affects the practitioner's knowledge standard and documentation obligation. Implementing regulations may be pending; verify at IRS.gov.

Head of Household filing status

Head of household filing status is the fourth element covered by the IRC 6695(g) due diligence requirement. Verify whether the OBBBA modified the definition of qualifying person for head of household status, the standard deduction for HOH filers, or the tax rate bracket applicable to HOH at IRS.gov. Any change to HOH rules under the OBBBA affects Form 8867 compliance for that filing status. Implementing regulations may be pending; verify at IRS.gov.

Due diligence practice implications

The OBBBA's credit modifications, wherever they land, do not change the core due diligence obligation: a practitioner must ask all required questions, apply the knowledge standard, and complete Form 8867 based on current law. The $650 per-failure penalty applies regardless of whether the underlying eligibility rule changed. Before TY2026 filings begin, practitioners should obtain the updated Form 8867 instructions from IRS.gov, confirm that their due diligence checklists reflect OBBBA-modified rules, and document their research. See the IRC 6694 and 6695 preparer penalty framework guide for the full penalty structure.

Section 4: QBI and Pass-Through Changes -- IRC 199A Under the OBBBA

As of June 2026, verify current law and IRS implementing guidance at IRS.gov; the OBBBA was recently enacted and implementing regulations may be pending. The following section covers OBBBA modifications to the IRC 199A qualified business income deduction framework.

The prior-law IRC 199A framework

Under TCJA, the IRC 199A deduction allowed individual owners of pass-through businesses (sole proprietors, S corporation shareholders, partnership partners, and trust and estate beneficiaries) to deduct up to 20% of their qualified business income (QBI) from each qualified trade or business, subject to W-2 wage and unadjusted basis in acquired property (UBIA) limitations for taxpayers above the income threshold, and subject to phase-out for specified service trades or businesses (SSTBs). These TCJA provisions were scheduled to expire after 2025. The OBBBA enacted modifications that practitioners must verify at IRS.gov before applying to TY2026 returns.

OBBBA modifications to IRC 199A

The OBBBA enacted changes to the IRC 199A framework including, potentially, the deduction percentage, income thresholds at which the W-2 wage limitation applies, the SSTB phase-out range, and the treatment of certain business types. Whether the OBBBA extended the prior 20% deduction rate, modified it, or replaced it with a different structure must be confirmed at IRS.gov. Practitioners preparing TY2026 S corporation, partnership, and Schedule C returns must confirm the current OBBBA QBI deduction percentage, threshold, and limitation framework before computing Form 8995 or Form 8995-A. Implementing regulations may be pending; verify at IRS.gov. The OBBBA also restored immediate domestic research and experimental expensing under IRC 174A, which requires a Form 3115 accounting method change; for the Rev. Proc. 2025-23 and 2025-28 procedures and the IRC 481(a) adjustment mechanics, see the Form 3115 OBBBA method change guide.

W-2 wage and UBIA limitations

The TCJA W-2 wage limitation and the UBIA-of-qualified-property alternative limit under IRC 199A(b) apply above the income threshold. Whether the OBBBA modified these limitations, the income threshold at which they apply, or the way they interact with the deduction percentage must be verified at IRS.gov. The TY2026 Form 8995-A (for taxpayers with multiple businesses or above-threshold income) will reflect any OBBBA-mandated changes; confirm the current form instructions at IRS.gov before using prior-year procedures. Implementing regulations may be pending; verify at IRS.gov.

Specified service trades or businesses (SSTBs)

Under TCJA, SSTBs (including health, law, accounting, consulting, financial services, and performing arts) were subject to a phase-out of the QBI deduction for taxpayers whose income exceeded the applicable threshold. Whether the OBBBA modified the SSTB definition, the phase-out range, or the threshold must be confirmed at IRS.gov. Practitioners advising pass-through business owners in professional service fields should not assume the prior-law SSTB framework continues unchanged into TY2026 without this verification. Implementing regulations may be pending; verify at IRS.gov.

Pass-through entity-level tax (PTET) considerations

Many states enacted pass-through entity tax (PTET) elections as a workaround to the TCJA SALT cap. Whether the OBBBA's modifications to the SALT cap affect the PTET strategy, or whether OBBBA enacted any federal provision specifically addressing PTET deductibility, must be verified at IRS.gov. The interaction between the OBBBA SALT cap changes and state PTET regimes is an area where planning advice should be given only after confirming both federal implementing guidance and state guidance on any changes. Implementing regulations may be pending; verify at IRS.gov. For the full PTET election mechanics, the QBI ordering risk, and a state-by-state deadline tracker, see the pass-through entity tax PTET election and OBBBA guide. See the retirement plans guide for self-employed practitioners for OBBBA implications on SEP-IRA and Solo 401(k) contribution limits where relevant.

Section 5: Payroll and Self-Employment Provisions

As of June 2026, verify current law and IRS implementing guidance at IRS.gov; the OBBBA was recently enacted and implementing regulations may be pending. The following section covers OBBBA provisions affecting payroll taxes and self-employment taxation.

Self-employment tax and the SE deduction

Self-employment tax under IRC 1401 (Social Security and Medicare components) and the corresponding above-the-line deduction for one-half of SE tax under IRC 164(f) are foundational to Schedule C, Schedule F, and Schedule SE preparation. Whether the OBBBA enacted any changes to SE tax rates, the Social Security wage base interaction, the SE tax deduction, or the computation of net earnings from self-employment must be verified at IRS.gov. The Social Security wage base is adjusted annually; confirm the TY2026 figure at IRS.gov. Implementing regulations may be pending; verify at IRS.gov.

Employer payroll provisions

For practitioners who also prepare Forms 941, W-2, and business payroll, verify whether the OBBBA enacted any changes to employment tax rates, employer credits (such as the Work Opportunity Tax Credit or the Employee Retention Credit wind-down provisions), or reporting requirements. The OBBBA may have modified or sunset certain employer tax credits that affected Form 941 computation. Implementing regulations may be pending; verify at IRS.gov before preparing TY2026 payroll tax returns. For the OBBBA disallowance of late-filed Q3/Q4 2021 Employee Retention Credit claims, the extended 6-year audit statute, the expanded IRC 6700 and 6701 promoter penalties, and CP320B notice response steps, see the ERC OBBBA audit defense guide.

Tip reporting and service industry provisions

Verify whether the OBBBA enacted any changes to tip income taxation, the FICA tip credit under IRC 45B, or tip reporting obligations for service industry employers at IRS.gov. Any changes in this area affect both Form 8846 (Employer Credit for FICA Taxes on Tips) and the correct treatment of tip income on employee W-2s. Implementing regulations may be pending; verify at IRS.gov.

Retirement plan contribution limits and small employer provisions

The SECURE 2.0 Act (2022) enacted a series of retirement plan changes on a rolling effective date schedule. The OBBBA may have modified or accelerated certain SECURE 2.0 provisions, or enacted additional retirement plan changes. Verify the TY2026 contribution limits, catch-up contribution rules, and any OBBBA modifications to small employer retirement plan credits at IRS.gov. See the retirement plans for self-employed practitioners guide for the full framework, and the SECURE 2.0 Act 2026 Roth catch-up and plan amendments guide for the mandatory Roth catch-up (operational January 1, 2026, with good-faith relief through January 1, 2027) and the December 31, 2026 plan amendment deadline. Implementing regulations may be pending; verify at IRS.gov.

Section 6: Collection and Enforcement Changes -- IRC 7345 Threshold, CSED Tolling Rules

As of June 2026, verify current law and IRS implementing guidance at IRS.gov; the OBBBA was recently enacted and implementing regulations may be pending. All dollar thresholds in this section must be confirmed at IRS.gov before advising clients.

IRC 7345: Seriously delinquent tax debt and passport certification

The IRC 7345 threshold for certification of a taxpayer as having seriously delinquent tax debt, which triggers notification to the State Department and potential passport revocation or denial, was approximately $62,000 as of early 2026, subject to inflation adjustment. Verify the current inflation-adjusted threshold at IRS.gov before advising any client on this issue. Whether the OBBBA enacted any change to the IRC 7345 threshold, the exception framework (installment agreements, CDP hearing pending, OIC pending, CNC status, innocent spouse, disaster relief), or the notification procedures must be verified at IRS.gov. See the IRC 7345 passport certification practitioner guide for the full representation protocol. Implementing regulations may be pending; verify at IRS.gov.

Collection Statute Expiration Date (CSED) tolling

The 10-year CSED under IRC 6502 governs the IRS's ability to collect a tax liability after assessment. Tolling events extend the CSED beyond 10 years: a pending OIC, a Collection Due Process hearing, bankruptcy proceedings (plus six months under IRC 6503(h)), and a taxpayer's absence from the United States are among the standard tolling events. Whether the OBBBA enacted any modification to CSED tolling rules, the CSED period itself, or the interaction between OBBBA-created resolution options and CSED must be verified at IRS.gov. Practitioners handling collection cases must not assume CSED rules are unchanged from pre-OBBBA law without this verification step. See the CSED practitioner strategy guide for the full tolling event analysis. Implementing regulations may be pending; verify at IRS.gov.

Installment agreement thresholds and streamlined procedures

Whether the OBBBA modified installment agreement thresholds, streamlined IA eligibility criteria, or the procedures for guaranteed and simplified installment agreements must be verified at IRS.gov. Any change to IA thresholds affects which resolution tools are available to clients at particular balance levels. See the IRS installment agreement preparer guide for the current IA framework. Implementing regulations may be pending; verify at IRS.gov.

Offer in Compromise program changes

Verify whether the OBBBA enacted any changes to the OIC program at IRS.gov: the application fee, the reasonable collection potential (RCP) calculation methodology, the doubt-as-to-liability ground, or the grounds for rejection and appeal. OIC practice is highly sensitive to any legislative change affecting the RCP calculation, because the RCP drives the minimum acceptable offer amount. See the IRS OIC preparer guide for the full OIC framework. Implementing regulations may be pending; verify at IRS.gov.

Cryptocurrency and digital asset enforcement provisions

The OBBBA may have enacted or modified reporting requirements, broker reporting rules, or enforcement provisions for digital assets. The Infrastructure Investment and Jobs Act of 2021 had already enacted expanded digital asset broker reporting requirements; whether the OBBBA modified, delayed, or accelerated any of those provisions must be confirmed at IRS.gov. See the cryptocurrency tax preparation guide for tax preparers for the digital asset reporting framework. Implementing regulations may be pending; verify at IRS.gov.

Section 7: Preparer-Specific Provisions -- Penalty Thresholds, EA and AFSP Rules, PTIN

As of June 2026, verify current law and IRS implementing guidance at IRS.gov; the OBBBA was recently enacted and implementing regulations may be pending.

Preparer penalty thresholds under IRC 6694 and 6695

Whether the OBBBA modified any preparer penalty thresholds under IRC 6694 (unreasonable position, willful understatement) or IRC 6695 (copy to taxpayer, signature, PTIN, record retention, e-file, due diligence) must be verified at IRS.gov. As of June 2026, the following penalty benchmarks are in effect, subject to verification and any OBBBA modifications: the IRC 6695(g) EITC due diligence penalty is $650 per failure (2026 inflation-adjusted figure; verify at IRS.gov); the IRC 6694(b) willful understatement penalty is the greater of $5,000 or 75% of income derived from the return (statutory formula, not an inflation-adjusted figure); and the IRC 6695(a) e-file penalty is $50 per return (statutory, not inflation-adjusted, but verify at IRS.gov). See the IRC 6694 and 6695 preparer penalty framework guide for the full penalty analysis. Implementing regulations may be pending; verify at IRS.gov.

PTIN program changes

The PTIN program under IRC 6109 requires all compensated preparers to obtain and use a PTIN. Whether the OBBBA enacted any changes to PTIN requirements, PTIN fees, or the legal basis for PTIN regulation must be verified at IRS.gov. The IRS PTIN program has been the subject of prior litigation; any OBBBA provision affecting its legal authority is particularly important for practitioners to confirm before relying on PTIN-related regulations. Implementing regulations may be pending; verify at IRS.gov.

Enrolled Agent and AFSP representation scope

Enrolled Agents have unlimited representation rights before the IRS under Circular 230. AFSP participants have limited representation rights: they may represent taxpayers during examination of returns they prepared, and assist with customer service matters, but AFSP representation does not extend to Collection proceedings before Revenue Officers, CDP hearings, or other representation actions beyond the examination of prepared returns. Whether the OBBBA enacted any change to AFSP representation scope must be verified at IRS.gov. AFSP participants should not assume their representation authority expanded under the OBBBA without confirming at IRS.gov; the AFSP representation scope is set by Circular 230 regulation, which can be updated separately from legislation. See the enrolled agent CE requirements and renewal guide for the EA credential framework. Implementing regulations may be pending; verify at IRS.gov.

Tax Pro Account and IRS online account requirements

IRS Tax Pro Account is an online tool that allows practitioners to view and manage client authorizations. Access requires an ID.me verified identity account. Clients must also have an IRS online account (with ID.me verification) before a practitioner can use Tax Pro Account to view their account information. Whether the OBBBA enacted any changes to the Tax Pro Account framework, e-services access, or CAF authorization procedures must be verified at IRS.gov. Implementing regulations may be pending; verify at IRS.gov.

Section 8: Form and Software Implications -- Which IRS Forms Change for TY2026

As of June 2026, verify current law and IRS implementing guidance at IRS.gov; the OBBBA was recently enacted and implementing regulations may be pending. IRS form updates for TY2026 will be released on a rolling basis; verify current draft and final forms at IRS.gov/forms before the TY2026 filing season opens.

Forms expected to be affected by OBBBA provisions

Based on the OBBBA's scope, the following forms are likely to be updated for TY2026, though the specific changes to each form depend on implementing regulations and IRS administrative guidance that may not yet have been published as of this guide's date. Verify current form versions at IRS.gov before using any form for TY2026 preparation:

• Form 1040 Schedule A (SALT cap modifications)
• Form 6251 (AMT computation, if exemption amounts changed)
• Form 8995 and Form 8995-A (QBI deduction, if IRC 199A percentage or thresholds changed)
• Form 8812 (Child Tax Credit and ACTC, if CTC amounts or refundability changed)
• Form 8867 (Due diligence, if EITC, CTC, AOTC, or HOH eligibility rules changed)
• Schedule SE (if SE tax rates or computation changed)
• Any forms relating to digital asset reporting, if OBBBA accelerated or modified those requirements

This list is not exhaustive. The IRS releases updated forms on a rolling basis, and the TY2026 forms will not all be finalized before the filing season. Practitioners should monitor the IRS.gov/forms page, subscribe to IRS e-News for tax professionals, and confirm with their tax software vendor (such as CCH TaxWise) that OBBBA-driven form changes are reflected in the TY2026 software release before filing. See the AUR and CP2000 practitioner guide for how incorrect form entries and misreported figures generate CP2000 notices in post-filing review.

Software update verification

No tax software can reflect OBBBA changes until the IRS releases implementing guidance and updated form specifications. Practitioners using any software, including CCH TaxWise, should confirm with the vendor that TY2026 OBBBA-affected computations are properly handled before filing returns that rely on those provisions. Software vendors release update bulletins when new guidance is incorporated; review those bulletins before filing returns that turn on OBBBA provisions. Implementing regulations may be pending; verify at IRS.gov.

Section 9: Year-End Client Planning Checklist -- Action Items Before December 31, 2026

As of June 2026, verify current law and IRS implementing guidance at IRS.gov before relying on any OBBBA provision in client planning conversations; the OBBBA was recently enacted and implementing regulations may be pending. This checklist should be updated as additional IRS guidance is issued.

Section 10: Regulatory Implementation Status -- Guidance Issued vs. Pending (as of June 8, 2026)

When major tax legislation is enacted, implementing guidance from the IRS arrives in stages: first, Notice and Revenue Procedures providing interim guidance; then proposed regulations; then final regulations. The OBBBA is no exception. As of June 2026, some OBBBA provisions have IRS guidance available, while others are operating under the statutory text alone or under interim guidance that has not been finalized.

How to check current guidance status

The primary sources for OBBBA implementing guidance are: the IRS.gov newsroom (IRS.gov/newsroom), IRS Notices and Revenue Procedures published in the Internal Revenue Bulletin (IRS.gov/irb), and IRS.gov's dedicated OBBBA information page (verify current URL at IRS.gov). Practitioners should subscribe to IRS e-News for Tax Professionals at IRS.gov, which provides email notification when new OBBBA guidance is released.

Practitioner guidance when regulations are pending

When a client's return requires a position on an OBBBA provision for which implementing regulations have not been finalized, the practitioner's obligation under IRC 6694 is to take a position with at least substantial authority (more likely than not under the higher willful standard; more than one-in-three under the reasonable basis disclosure path). Document the basis for the position in the workpaper. If the position relies on the statutory text alone, note that explicitly. Consider Form 8275 disclosure for positions that do not meet the substantial authority standard but have a reasonable basis. See the IRC 6694 and 6695 preparer penalty framework guide for the disclosure standards and penalty framework.

Amended return considerations

When implementing regulations are finalized and clarify a position taken on a previously filed return, practitioners should evaluate whether an amended return (Form 1040-X) is warranted. In some cases, the finalized regulation may provide a more favorable treatment than the position taken; in others, it may require a correction. Discuss with clients the possibility that TY2026 returns may need amendment as OBBBA guidance is finalized, and document that discussion. Implementing regulations may be pending; verify at IRS.gov.

Section 11: Internal Resource Map -- ATP Guides for Each OBBBA Practice Area

Each OBBBA practice area connects to a deeper practitioner resource. The following map links OBBBA sections to the ATP guide covering the relevant framework:

• Collection enforcement (IRC 7345, CSED): CSED Practitioner Strategy Guide and IRC 7345 Passport Certification Guide
• Preparer penalties (IRC 6694, 6695): IRC 6694 and 6695 Preparer Penalty Framework Guide
• EITC due diligence and Form 8867: EITC Due Diligence and Form 8867 Guide
• Installment agreements: IRS Installment Agreement Preparer Guide
• Offer in Compromise: IRS Offer in Compromise Preparer Guide
• Digital assets and cryptocurrency: Cryptocurrency Tax Preparation Guide for Tax Preparers
• AUR and CP2000 (OBBBA form changes driving notices): AUR, CP2501, and CP2000 Practitioner Guide
• Enrolled Agent CE and renewal: Enrolled Agent CE Requirements and Renewal Guide
• Retirement plans and self-employed provisions: Retirement Plans for Self-Employed Practitioners Guide

Related Practitioner Guides

The following guides cover OBBBA provisions that are among the highest-priority topics in any OBBBA practitioner update and are referenced throughout this practice guide.

• IRC 163(j) Business Interest Limitation OBBBA Guide -- the OBBBA permanently restored EBITDA-based adjusted taxable income for IRC 163(j) beginning in 2025; this is one of the most significant OBBBA business provisions affecting pass-through owners, C corporations, and real estate investors and is a core topic in any OBBBA practitioner update.
• IRC 164 SALT Deduction Cap OBBBA Guide -- the OBBBA raised the SALT cap from $10,000 and added a phase-down for high-income taxpayers; understanding the new cap and the PTET bypass is essential for individual clients in high-tax states and is among the most-discussed individual provisions in the OBBBA preparer update.
• IRC 174A Research Expenditures OBBBA Guide -- the OBBBA restored immediate 100% expensing of domestic R&E costs and established new Rev. Proc. 2025-28 transition rules; domestic R&E expensing is one of the most consequential OBBBA changes for technology, manufacturing, and pharmaceutical clients.
• Schedule 1-A OBBBA Tips and Overtime Deductions Guide -- the OBBBA created new above-the-line deductions for tip income and overtime pay reported on Schedule 1-A; these individual deductions are among the highest-volume client questions in the 2026 filing season and are a required topic in any OBBBA practitioner update.
• IRC 263A UNICAP Uniform Capitalization Rules Practitioner Guide -- the One Big Beautiful Budget Act significantly raised the gross receipts threshold for the IRC 263A(b)(2) small business exception; practitioners advising clients with gross receipts near the new threshold should verify the current OBBBA-indexed threshold at IRS.gov and run the IRC 448(c)(2) aggregation rules before concluding the exception applies; clients newly exempt from UNICAP under the OBBBA threshold may have transition-year Section 481(a) adjustments requiring planning.
• IRC 162(a) and 162(e) business expense and lobbying -- Ordinary and necessary standard, lobbying disallowance, Cohan rule, and OBBBA 2026 meal changes.

Frequently Asked Questions