As companies assess the favorable corporate tax changes introduced by the One Big Beautiful Bill Act, some may find an unwelcome surprise: the same provisions that reduce taxable income may increase exposure to the corporate alternative minimum tax (CAMT). The OBBBA’s expensing benefits and extended credits from the Tax Cuts and Jobs Act can generate cash tax savings, but they do not reduce adjusted financial statement income. As a result, even when regular tax liability decreases, CAMT liability may still arise. Key areas where this tension is most pronounced include the treatment of research and experimental  expenditures under section 174, the interest limitation under section 163(j), and the newly defined foreign-derived deduction-eligible income. How should corporations approach planning when statutory incentives and CAMT rules conflict? What does this dynamic suggest for future legislative or regulatory responses? 

The repeal of green tax credits in the One Big Beautiful Bill Act significantly alters the United States' approach to clean energy, curtailing incentives that had stimulated investment and job growth in the solar, wind, and electric vehicle sectors. It also challenges prior assumptions about long-term tax expenditure planning and the role of tax policy in advancing environmental goals. Proponents argue that it improves fiscal discipline and simplifies the tax code by eliminating complex, industry-specific provisions. What is the net revenue impact of these changes over the next decade? Will they slow capital formation in energy markets? How will companies adjust their strategies to accommodate this change in policy priorities?  Will the quick repeal of these credits affect how companies react to future incentives? 

The IRS is at a pivotal moment for its future, and who better to weigh in than four former commissioners who led the agency through decades of change? As demands for greater efficiency and accountability grow, questions emerge about how the IRS can operate effectively with limited resources. What does a well-structured IRS look like in today’s fiscal climate? How can the agency meet goals for collections, privacy, and service amid calls for government downsizing? And what insights can these leaders offer to guide reform efforts that rise above politics?

The future of the OECD’s pillar 2 project and U.S. involvement remains a focal point of international tax discussions. As the global minimum tax continues to gain traction across jurisdictions, questions emerge about the direction of U.S. policy under the new administration. Can pillar 2 function effectively without U.S. participation? Are there possible compromises between the OECD and U.S. positions? How will companies be affected in a fragmented system?