Editor's note: The fourth quarter of 2025 was characterized by a steady stream of Treasury and IRS implementation guidance for OBBBA, notices, revenue procedures, fact sheets, and updated forms. By December 31, 2025, the practical contours of OBBBA were substantially clearer than on enactment day. This essay catalogs the key Q4 2025 guidance and how we applied it.
The 180 days following OBBBA's July 4, 2025 enactment ² produced more IRS administrative guidance than any comparable period in recent tax history. The agency issued at least 23 distinct notices and 4 revenue procedures specifically implementing OBBBA provisions, plus updates to dozens of forms, instructions, and Internal Revenue Manual sections. For our practice, October through December 2025 was the period when many open questions from July's first-reading analyses got answered.
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