For background on the Congressional Review Act, how it works, and its application to tax rules, see our recent explainer: taxlawcenter.org/the-federal-...

The Tax Law Center has written recently about this guidance and how it contributes to the administrative erosion of CAMT: taxlawcenter.org/blog/a-look-...

This agreement will further reward non-compliance and fraud, and it will deny taxpayers the technological upgrades and improved experience that they deserve."

taxlawcenter.org/blog/stateme...

It rescinds more than half of the Inflation Reduction Act funds remaining, and at current spending rates the remainder would almost certainly be exhausted during the current administration.

The agreement cuts base IRS funding, including enforcement, by over one-third relative to its 2010 level, adjusted for inflation.

However, by expanding transfer authority, the agreement would give the Trump administration greater flexibility in using the appropriated funds and potentially allow it to paper over the severity of the cuts in the near term, even as the cuts set the IRS up to fail in future administrations.

"The appropriations agreement’s record cuts in the IRS base budget and nearly $12 billion rescission of funding for IT upgrades guarantee a worse taxpayer experience and more non-compliance.

See more of our recent work on CAMT, including a recent article that specifically addresses industry lobbying for CAMT guidance on R&E expensing that is contrary to the purpose of the statute: (7/7) taxlawcenter.org/blog/stateme...

There are many debates about CAMT’s merits, but Treasury does not have the authority to simply disregard provisions of the law based purely on its policy preferences." (6/7)

Any industry lobbyists saying that this consequence was unanticipated failed to see the clear and obvious impact of the statute. (5/7)

Such a carveout would continue the recent trend of guidance that grants taxpayers CAMT tax cuts that are not contemplated by the statute. Further, it would implement a change to the CAMT rules that Congress had a clear chance to enact in the OBBBA but chose not to. (4/7)

It is hard to imagine how this carveout could be justified under statutory authority, and the Tax Law Center will scrutinize any eventual guidance for whether the guidance has any justification and is authorized by the statute. (3/7)

"Treasury should not issue guidance allowing retroactive R&E expensing for CAMT purposes since that would violate the purposes of the statute and would be nothing more than yet another tax cut to large corporations that Congress elected not to provide in OBBBA. (2/7)

Cutting discretionary funding for information technology would force the IRS into greater reliance on a finite pot of IRA funds—while those same funds are rescinded in another bill. Congress should reject these budgetary shell games and adequately fund the IRS.

It appears the administration is heading towards trying to wrongly deny tax credits to families and workers who are clearly eligible under the provisions of the tax code. That could affect many people lawfully present in the U.S., and could include denying Child Tax Credits to U.S. citizen children.