Since the One Big Beautiful Bill Act (OBBBA) was signed into law on July 4, the IRS and Treasury have faced the undertaking of implementing its new tax provisions. This effort comes amid a period of leadership transitions: several senior officials are serving in multiple key roles, and new positions have been created to support day-to-day operations. The combination of new policy initiatives and leadership adjustments could present an uncertain environment for businesses, nonprofits, and individual taxpayers as they wait for direction and guidance to navigate new tax laws.
The Implementation Challenge
Treasury recently released a roadmap for what to expect from its regulatory team in the coming months. This latest “Priority Guidance Plan” is more narrowly focused than previous versions and contains a shorter agenda centered on implementing both OBBBA and the Trump Administration’s broader deregulatory goals.
Read top to bottom, expect Treasury and the IRS to focus on guidance related to OBBBA’s individual provisions that take effect first, like tax relief for tipped and overtime wages, Trump accounts, and auto loan interest. Other provisions, such as those affecting scholarship-granting organizations and multinational corporations, are expected to take longer, likely extending into next year. These measures will require extensive coordination across Treasury and the IRS, and any delays from staffing shortages or the recent shutdown could slow progress.
Under ordinary circumstances, implementing OBBBA would be a formidable task. With senior officials rotating frequently and others managing multiple roles, the agency team is juggling numerous responsibilities beyond the new law. Certain pending regulations, especially those under consideration for deregulatory changes, may not be finalized until next year, creating uncertainty for businesses, nonprofits, and individual taxpayers. This staggered approach underscores the need for close monitoring and proactive planning during the rollout.
Agency Leadership in Flux
In less than a year, Doug O’Donnell, Melanie Krause, Gary Shapley, Michael Faulkender, Billy Long, and now Treasury Secretary Scott Bessent—who stepped in after Long’s removal in August—have served as IRS Commissioner.
Compounding turnover in leadership, several top Treasury officials are managing multiple senior roles simultaneously. Scott Bessent currently serves as both Treasury Secretary and Acting IRS Commissioner, overseeing two of the government’s most critical financial agencies. Ken Kies, confirmed in June as Assistant Secretary for Tax Policy, has also been acting as IRS Chief Counsel. Derek Theurer, advanced by the Senate Finance Committee to serve as Deputy Undersecretary of the Treasury, is expected to coordinate Treasury’s response to OBBBA, while simultaneously executing his responsibilities as Acting Deputy Secretary which was left vacant after Faulkender’s departure in August.
In a move to enhance operational efficiency, Bessent appointed Frank Bisignano as the CEO of the IRS, a newly created role responsible for overseeing daily operations. Bisignano, who continues serving as Social Security Commissioner, now manages two of the largest administrative bodies in government. The dual responsibilities of Bessent, Bisignano, Kies, and Theurer highlight the depth of the workforce demands across Treasury and the IRS, even as the administration works to nominate a permanent IRS Commissioner.
For taxpayers and organizations, the period of transition can affect not just operations but also the timeline for guidance. Without a permanent IRS Commissioner and with key officials managing multiple roles, some regulatory actions are expected to proceed more slowly, while others may be prioritized.
Why It Matters
The combination of new tax laws, leadership transitions, and staffing adjustments means those writing the regulations face a particularly heavy workload. As a result, some provisions are prioritized for immediate implementation, while others take longer to finalize to ensure they receive the proper attention and consideration. This staggered pace may require additional time and resources for some entities to adapt effectively, particularly those with limited staff or capacity.
Businesses, nonprofits, and individual taxpayers would do well to begin planning for potential administrative complexity sooner rather than later, but all will need to closely monitor regulatory updates and remain flexible as the agencies continue to staff up and advance implementation.
Still, the anticipated Senate confirmation Derek Theurer could help Treasury and the IRS continue advancing guidance efficiently and provide additional clarity for taxpayers and organizations navigating the new law.
With contributions from Geoff Paul (Gpaul@integerpolicy.com).