Tax Notes Talk

2026 U.S. Tax Legislation Forecast

Tax Notes

Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2025 developments in U.S. tax legislation and speculates what may lie ahead in 2026.

For related tax news, read the following in Tax Notes:


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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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This episode is sponsored by Crux. For more information, visit cruxclimate.com/contact.

This episode is sponsored by Avalara. For more information, visit avalara.com.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

This transcript has been edited for clarity.

David D. Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: 2025 wrap-up.

We're continuing our tradition at the start of the new year of reviewing what happened in U.S. tax policy and looking ahead to what we can expect in the next 12 months.

Here to recap the 2025 highlights and make some predictions on 2026 is Tax Analysts Chief Operating Officer Jeremy Scott. Jeremy, welcome back to the podcast.

Jeremy Scott: Thank you. Always happy to be here.

David D. Stewart: Why don't we start off with a quick overview of the year that we just lived through. What happened in tax?

Jeremy Scott: This was obviously a huge year in tax. As always, when you have unified government, one of the top priorities of an administration is to push through a tax package because that's simply how most legislative priorities are accomplished today. So this was very, very busy.

And essentially the theme of the year was the Tax Cuts and Jobs Act and how to move on that in Congress. And with a very narrow majority in the House of Representatives and not a huge majority in this Senate, the Republicans had a difficult time doing that, although they did do it much faster than anyone expected. I think if people remember back in 2017, the Tax Cuts and Jobs Act essentially did not come together until the very end of the year, and Republicans struggled to even come up with a concept. This year, they were done by the middle of the year. Everything came together relatively quickly on what they were trying to do, and then they basically hammered it through.

And although they had a tough time convincing Republican holdouts in the House to vote for it, they were able to pass essentially a partisan bill that accomplished their legislative priorities and some of President Trump's campaign promises, although not always the way he implied they would be done. This is a very busy year in tax. Like I said, the first year of an administration often is, and this year was no exception.

David D. Stewart: Let's get into it. We've got this One Big Beautiful Bill Act, OB3. We haven't quite settled on a name yet. How significant a tax bill was this?

Jeremy Scott: Somewhat shockingly when you look at it, this is actually probably the largest tax bill ever passed. And I know that may surprise some people who think of 1986 or even think of the [President George W.] Bush tax cuts or even the original Tax Cuts and Jobs Act, because they all received a lot more legislative buildup, a lot more discussion throughout the year.

But the OB3 is an enormous piece of tax legislation. The reason it isn't quite as exciting as something like the TCJA or 1986 is it largely extends provisions that were already in place. They were very expensive provisions, but that is why the cost ends up being so high. And Republicans didn't really get into much of an offset game this time. They really weren't looking for ways to pay for what they were doing. They were going to do somewhere between $2 [trillion] and $3 trillion of tax cuts, and it was just about bringing the package in in a way that could convince a few of the outlier Republicans in the House in particular to vote for it.

It's a big bill. There's a lot in it, but it didn't excite people the way tax legislation in the past has excited people because not a lot of it was new. It extended all the individual rates. That was the big thing to not let those rates go back to their pre-2017 levels. That would've been a massive tax increase on essentially all income taxpayers. It is a permanent extension of those.

It went into some of Trump's promises. There is a bizarre deduction for income on tips and overtime that we will see how that plays out in [the] filing season next year. Essentially, the first $25,000 of tips and overtime is now exempt from taxation through a deduction.

That deduction seems straightforward, but it actually puts quite a lot of the burden on employers to classify the income correctly, which essentially means a lot of people who may have been a little fuzzy on how tips were being reported, both at the employer and employee level, to take advantage of that deduction are going to have to get a lot tighter on how they report it. But that was a Trump campaign promise that is in there. He creates a number of other smaller vehicles.

There are "Trump accounts," tax deferred savings accounts for children, which we just recently heard how some of them would be funded. Trump promised no tax on Social Security. We did not get that. Instead, we got a $6,000 deduction for people over 65. And so there will still be taxes on Social Security income. It's just many people who may get the very small amount of Social Security income no longer will pay it.

The big issue that held the bill up for a little while was what would happen with the SALT [state and local tax] deduction. There were Republicans that wanted to see the SALT cap, which TCJA put in, thrown out. Instead of having it thrown completely out, it's now been raised to $40,000, although that will expire in four years. So that's going to take a lot of taxpayers who were paying the SALT cap deduction, particularly individual taxpayers, out of it. They're going to be able to deduct now the full amount of state and local taxes that they're paying instead of being limited to that $10,000 cap, which was actually fairly low for people living in areas with high property taxes, not to mention high income taxes. So lots of individual provisions in the OB3.

It did some tweaking of some corporate provisions. It tried to make the research credit a little bit more attractive. We're discovering here at the end of the year that it might not have done so quite as much as people thought. Some of those accelerated research credit deductions that people thought they were going to get are going to be thrown out by the corporate alternative minimum tax, CAMT, as people call it. There's a lot of speculation on how the IRS and Treasury are going to handle that, but that was one corporate provision that was in there.

There's some changes to [foreign-derived intangible income and global intangible low-taxed income that] made it in there — nothing particularly significant, although perhaps significant to the people who care about those provisions. We did not get the retaliation tax that Republicans were promising last year. By that, I mean section 899, which would have allowed the president to retaliate against states to put certain types of taxes on the United States. This was the U.S.'s big push to essentially opt out of pillar 1 and pillar 2 or force pillar 1 and pillar 2 to come more in compliance with what the U.S. wants. They did not put that in there because of an agreement that was made with the G20 that would allow these alternate systems to exist.

We will see how that plays out. I think Republicans, if they thought they were going to get the deal they wanted from the G20, made a bit of a mistake because given how hard it was to pass OB3, the idea that they can just go back and do [section] 899 if they don't get what they want from the G20 seems a little far-fetched, but again, that's a 2026 problem.

And that's basically it. Again, big legislation, some other things in there, ICE, border enforcement, the wall, not really that relevant to tax, although relevant to perhaps people affected by those areas of government. But again, very large bill, probably the largest tax bill ever, did not get quite the excitement of some previous tax bills because it was just extending stuff that was already done.

David D. Stewart: Do you expect taxpayers to see the sort of compromised versions of Trump's promises on Social Security or tips — do you expect those to be seen as keeping those promises, or will people be a bit surprised when they actually go to file?

Jeremy Scott: I think on tips and overtime, most people are going to be pretty satisfied, particularly since many suspected that Trump and Republicans would drop that once they were in office. I think a lot of people were surprised how insistent the president was that that make it in and then how insistent leadership in the Senate and the House were to get that in. So I'm not sure you can be too upset about what ended up happening on tips and overtime. So I think people will probably be satisfied with that.

On Social Security, it's a little smoke and mirrors to put a deduction in and then say you've eliminated the tax on Social Security because you really haven't. How upset seniors will be, I'm not sure. A lot of them will pay significantly less in tax if they can qualify for this deduction if they're making only Social Security income.

I think that is a partial fulfilling of the promise. I think you will still hear seniors groups and lobbying groups that are focused on this issue pushing for more. I think they would like to see Social Security completely exempt from taxation. The problem is that tends to benefit the wealthy a lot more than it benefits some of the lower-income people. And so it's never been a high priority, and I think Trump maybe got it as far as he could.

I think the one where you may see people upset is in some of these swing districts, the SALT cap is a big deal. Not so much for voters, but for the people who donate to political campaigns. And I think even though this cap went up quite a lot, I think there were a lot of Republican and Republican-leaning donors who counted on it going away. And I think we'll see what happens in some of these blue states, how committed they are to some of these marginal House races since they couldn't get what they wanted out of the members that they'd get returned in 2024.

David D. Stewart: Would you expect that that gets revisited? I mean, it has to get revisited in four years, but is that something where there might be some momentum to try and take another bite at it?

Jeremy Scott: I think there's always going to be momentum here. I think the problem that Republicans have on the SALT cap is that at the moment, I think there is only one Republican from a state won by a Democrat, or [at least] very few Republican senators come from blue states. And so when you don't have Senate pressure, it's hard to get a provision over the finish line. And since basically all Republican senators are red state senators, and since most red states don't encounter the SALT cap to begin with — in fact, many red states don't even have an income tax — it's difficult to get the buy-in necessary to pull that totally back.

But each party is dependent on these marginal House seats to form their majority when they take and lose the House. And so I do think those members will always agitate for something. I don't think it's ever going to be a priority for Democrats to completely get rid of a tax on state and local income taxes. And so I don't think it's going to be their priority to remove this cap to go back to an unlimited deduction. And I think Republicans are going to have a hard time getting the Senate to move.

So yes, you will hear noise about this until it goes away. I don't think a cap is ever going to go away. I think the question is going to become much like, say with the estate tax, what is the level at which the cap is set, more than do we have a cap or do we not have a cap? And so yes, this will get revisited. You'll hear a lot about it. I think taxpayers who are looking to get something more generous than what they got this time are likely to be disappointed regardless of who controls the House, the Senate, and the White House.

David D. Stewart: Now, you mentioned the Trump accounts as one of the policies that came in. How significant of a new system are these accounts going to be?

Jeremy Scott: Yeah, I don't think these are going to be that significant. I think these are a publicity stunt. Other people could have a disagreement, but this is not likely to be a major part of the tax code. I think this is something to get the president's name on a vehicle that seems like a populous tax measure. They're likely to have a very small impact in the future.

David D. Stewart: Was there anything in OB3 that surprised you?

Jeremy Scott: I don't think so. I think a number of the green credits did a little better than I thought. I thought they might just outright repeal them all. They did repeal a ton of them, but they did let them phase out in a way that a lot of projects started during the Biden administration will be allowed to continue, provided they meet some of these eligibility requirements.

Now it's interesting on the green credits: The language that they passed and the language that they're going to enforce could be two different things, because one of the ways that they got some House Republicans on board with the bill was essentially they went and talked to Trump and said, "They're not repealing these, but we want you to crack down on them and make them almost impossible to get." And he said he was going to do that. And they issued some guidance through an executive order that said essentially, "No more projects," but the Treasury guidance doesn't say that.

And so I was actually a little surprised that they didn't just outright repeal it because I thought there would be more of an emphasis on finding pay-fors, that they would essentially, they would have to buy the deficit hawks' votes more than they would have to buy the more right-wing, more conservative votes from, say, like the Freedom Caucus. And instead it ended up being the reverse. The deficit hawks were not as hard to get on board with the bill as the very conservative members. And so they went about these green credits in a different way than I expected. So that's about the only thing that surprised me.

I was surprised they got it through to some extent, given the small margins in the House. But I think one of the things we're going to see going forward is that essentially if you don't pass a tax bill, you are not going to accomplish any of your agenda. And I think that as negotiations were happening, essentially some of these members were told, "If we fail this, if this bill does not go through, President Trump will accomplish nothing in his first two years." And that scared a lot of people and made getting it through easier than maybe I would've expected in a House with only 220 Republicans; you can only lose a couple of votes.

So in some ways, it was surprising they passed it. That was one of the more interesting aspects, but I guess not too shocking because parties seldom completely abdicate getting anything done when they have an opportunity in that first part of an administration. Even [President] Biden, who suffered the setback of not getting Build Back Better through Congress in the first year of his term, got the IRA [Inflation Reduction Act] through a little bit later. And so eventually, they did get reluctant members to come on board. So I think we shouldn't be too surprised if even with narrow majorities, we start to see completely partisan bills pass in the future.

David D. Stewart: Were there any questions left unanswered by OB3 that will have to be dealt with in the future?

Jeremy Scott: Well, they made most of the stuff permanent. So we're not going to have these sort of cliff effects, at least on many of the provisions since we talked about the SALT cap. So that's not really an open question.

I still think you're going to have open questions on how the United States, pillar 2, and this international consensus on a minimum tax come together. I think there's an open question, if the G20 agreement falls apart, do they go back and revisit this [section] 899 retaliatory tax? Will there be changes that we have to make to our international tax regime to comply with pillar 2 because our companies are essentially getting hammered in other jurisdictions if we don't make those changes? Those are open questions.

I know everyone in the United States likes to think pillar 2's not going to affect us: "It's dead. Don't worry about it." But that's not quite how it's working. It may still come to that. It may all fall apart internationally, but if it doesn't fall apart internationally, there will be the need for some type of legislation in the future to deal with that. On the individual provisions within OB3, I think a lot of it's settled at this point. I think there aren't really that many open questions.

I think it's an open question to some extent, say, if we have a new party in control the next time there's a presidential election, could they revisit these individual rate cuts? Do they look to raise them? Because that could raise significant revenue, [but it's] very, very, very hard to undo individual rate cuts, as we learned with the Bush tax cuts; even once [President] Obama was in, even once Obama had 60 seats in the Senate and just an enormous House majority, there was no appetite for tackling the individual rates. I think they ended up letting one expire, and that was the very upper part of it.

So that might not be as big of an open question as we think, but OB3 did, like I said, it did a lot better at addressing much of what the Republicans had to address than many people thought it would, given the slim majorities. And now it's done, and we'll see how it plays in the midterms.

David D. Stewart: Is there any way of getting to a stable tax system where major changes aren't needed? Is this getting us any closer to that sort of system or further away?

Jeremy Scott: No, I think this is getting us further away. And I think the one reason you can tell that is these bills are all passing with no bipartisan support. There's absolutely no effort being made to get any Democratic buy-in to Republican tax cuts, and there's no Democratic effort being made to get Republican buy-in to Democratic tax priorities.

And also because of the way the Senate works and because of the way we have structured a lot of our code, the tax code is where you can accomplish major policy objectives. We even tried to accomplish healthcare reform through the tax code. So I think what you're going to see is anytime there's a new administration and anytime that administration has control of Congress, they're going to use the tax code to make major changes. They're going to use the reconciliation process, and they're going to use tax changes.

And so that means basically huge elements of the tax code are going to come up for debate every time there's a new administration. And so that is going to defeat a lot of efforts toward having a stable system that you can predict what the revenue is going to be, you can predict what the deficit's going to be, you can predict what policy is going to be going into the future.

Now, some things, like I said, they do become settled. It's hard to undo individual rate changes, and that's something Republicans have capitalized on, but it might not be that hard to undo, say, corporate rate changes. There was a lot of talk [that] if the Democrats had won the last election, they were going to raise the corporate rate. That would have been unheard of, say, 10, 15 years ago. But since we pushed the rate so much lower, I think it's now become an open question. It's become something that can be played with.

And so I think if you're hoping for a stable tax system, if you're hoping to have, say, more than five years of predictability, you're going to be disappointed because every fourth year, you're going to have a presidential election, and that's going to bring an impetus to make changes to the United States through the tax code because that's basically the only type of legislation that gets passed anymore.

David D. Stewart: Moving outside of the tax code to the other issue that raises revenue: tariffs. How significant were the tariff changes over the course of the year?

Jeremy Scott: Yeah. Well, tariffs were arguably an even bigger issue than taxes this year. President Trump liked tariffs in his first term. He talked about tariffs, only put a few of them in place. And in fact, many of the ones he put in place stayed in place during the Biden administration. So they weren't all that controversial, but it was a bit of a novel use of tariffs to set trade policy.

Yeah, Trump took all the guardrails off when he came into office this year. He is more than willing to use tariffs and certain emergency powers granted to the presidency by Congress to affect trade policy, to affect the international economy, to affect domestic manufacturing. We have entered an entire new era of how trade will be done if these tariffs stay in place. Trump put tariffs on basically every country, an across-the-board 10 percent tariff, put larger tariffs on certain other countries, including key trade partners, not just China, but the European Union, Canada, Mexico, arguably violating trade agreements that are already in place, which was interesting, but tariffs were enormous.

And they're raising enormous amounts of revenue. They are a larger part of the economy than we used to think. They could be raising up to $60 [billion] to $70 billion a month at this point. Hundreds of billions of dollars have already been collected. That's not just change. That is an enormous impact on the economy. We've seen it in some of the price movements. It's controversial to say so, but there's very little doubt that tariffs have affected prices in some ways, and which is why Trump took some of them down here in the late fall, particularly on food products.

This was a big year for trade policy in the sense that tariffs are back. We have a 10 percent tariff across the board, a number of higher tariffs. Those tariffs are intended to stay in place to accomplish the president's objectives of encouraging domestic manufacturing and, frankly, raising revenue.

So yeah, tariffs were a big deal this year. They got a lot more attention than taxes, probably undeservedly so. That tax bill, like I said, was enormous, but many people were focused on tariffs because they were so new, because they could be implemented, according to the White House, by the president at his whim, basically. And so yes, it was a big year for tariffs.

David D. Stewart: Speaking of those emergency powers that were being used to implement these tariffs, they got a hearing in front of the Supreme Court. We're still waiting on a decision. What sort of answer are you expecting to see from the Supreme Court?

Jeremy Scott: Yeah. Basically since Trump used his power in such a novel way, it was challenged. Usually the powers that he's relying on for these tariffs have been used to impose sanctions for a specific purpose. Usually they've had a set amount of time put on them. So you don't just say 10 percent on every country in the world. You say you're putting sanctions on Iranian goods because you're attempting to influence their policy or to punish them for things they've done under the current regime.

What Trump has done is a massive expansion of that type of power, and it did get challenged in the courts. It went quickly up to the Supreme Court, who had a hearing. At the hearing, it seemed that justices, including conservative justices, were very skeptical of how the administration had used these tariff powers. And so I think most people are expecting them to limit or even strike down the tariffs in some way.

This would obviously be an enormous blow to the Trump administration, which has relied on tariffs so extensively for trade and international policy. So I think people are expecting that. I don't think we know quite what's going to happen when or if the Supreme Court does that because it was such a big part of Trump's agenda. Treasury Department says they can implement these tariffs differently. If they could, you would've expected them to have done it differently because this is such a different use of these emergency powers.

I expect the Supreme Court to limit the tariffs in some way, if not throw them all out. If not, basically say, "This is not a proper use of executive power. Congress did not delegate all tariff power to the White House." And that will change how the Trump administration has to approach the last three years of his term. And it will throw into chaos a lot of its trade negotiation power. And I don't think we know quite all the implications of that. But I think many people would be shocked if the Supreme Court sides with the administration on this case.

David D. Stewart: Turning to tax administration, one of the big issues going on this year was DOGE [the Department of Government Efficiency] and a lot of cuts happening in the government. What sort of effect have the reductions in force and deferred resignations had at the IRS?

Jeremy Scott: Yeah, so this was a giant year for tax administration. I think people forgot about DOGE in the second half of 2025, but they won't forget about them in the first half of 2026 because that's when you're going to see a lot of the effects of the cuts at the IRS affect the tax filing season.

So essentially what happened is massive reductions in force at the IRS, both through voluntary resignation programs, reduction in forces. I believe the IRS was down anywhere from 20 to 25 percent of its high, if not more. It's very difficult to know exactly what happened because many of the RIFs in particular have been challenged in court and may or may not be in full effect.

And also we don't know how many employees have been put on leave and are still getting paid but aren't actually working, because there's the category of people who are gone; the category of people the administration wants gone, but courts have allowed to stay; and then the category of people the administration intends to force out, but have on this form of administrative leave.

So we don't know quite what is going on at the IRS, but we do know they have suffered massive reductions in staff. And that staff is primarily concentrated in enforcement more than service, although I expect that the service will be affected as well. That is going to undo a lot of what was happening in the Biden administration when you had a reemphasis on enforcement.

So I think we're going to have a very choppy filing season for anyone who has to interact with the IRS in a significant way. If you are dependent on the IRS for getting answers to questions, you're going to wait a lot longer and you might not get them. If you're dependent on the IRS to process complicated returns — in other words, if you're not just a [Form] W-2 filer trying to get your refund — you're likely to encounter delays.

I'll be interested to see when the start of filing season is and how it goes throughout, because usually the IRS is quite good at doing a rolling filing season, in the sense that if you file your taxes early, you get your refund a little bit faster, and that creates momentum for them to not have this big build up to April 15. We don't know what that's going to look like in 2026.

We also don't know a lot of what's going on because of the leadership changes at the IRS. This was an unprecedented year at the IRS in terms of its leadership. Trump strongly urged [IRS Commissioner] Danny Werfel to resign early so that he could replace him, and Werfel obliged. Werfel resigned before his term was up.

And so that was the first commissioner we had this year, and then we've gone through six more. It's been a wild year. Acting commissioners would take over. They would be confronted with a request from DOGE or the administration that they weren't comfortable with, and they would resign or they would be asked to resign. And so we cycled through a number of acting commissioners, many of whom had many decades of experience at IRS management.

We did get former Congressman [Billy] Long confirmed by the Senate to serve as Trump's IRS commissioner. He lasted less than two months. It's not entirely clear what happened, but he ran into problems dealing with the White House, and they asked him to leave with less than two months on the job.

This created another unprecedented situation where Trump essentially put the Treasury secretary in charge of the IRS and then appointed a CEO. And so we've never had an IRS CEO before. We don't know what that means. We don't know how that interacts with, say, the Senate's power to confirm a commissioner. Trump says he's going to nominate a new commissioner, but that has not happened as of the time that we're recording this.

So it's chaos at the top of the IRS. It got a little more stable in the second half of the year post-Long. But again, they've lost a lot of experience. They've lost a lot of high-level managers. We don't know what this means for policy. They still need to implement large parts of OB3. We're still waiting on a number of significant pieces of guidance. Don't know how the departures have affected that. Don't know what the status of chief counsel is. There is no Senate-confirmed chief counsel at the moment. The one nominee that Trump put up, who was former Chief Counsel Don Korb, has been withdrawn. So it's been a rough year for the IRS. There's been a lot of change. There's not a lot of stability, and I think we're in for a pretty choppy filing season as a result of it.

David D. Stewart: Considering all these cuts, does the IRS have what it needs to be effective going forward?

Jeremy Scott: I think the IRS is going to face significant challenges. I know that everyone cries wolf on this issue because the IRS has been a funding star for so long. It's like, "Oh, we've cut it so much. It'll never be able to recover. Oh, we've cut it so much there's going to be no voluntary compliance anymore."

I don't want to add to that course, but it is impossible to lose the number of employees they've lost, to lose the number of high-level managers and leaders that they've lost and to not have some effect on administration, to not have some effect on the efficiency of getting guidance out, to not have some effect on the quality of that guidance, to not have some effect on the IRS's ability to litigate.

They gutted the Justice Department's Tax Division. That is an important component of enforcement because they essentially are undefeated normally when they challenge large taxpayers. And so we lost a lot of qualified litigators. That's going to have an effect.

Will it move the voluntary compliance ratios in a way that actually significantly affects revenue? People have been predicting that for a long time. It hasn't really happened. Someday it will. You can't keep cutting and cutting and cutting and then expecting people to not realize, "I can essentially put anything down on my tax return and get away with it because they can't look at it." So someday all of this will have some effect. Will it be next year or the year after? It's hard to say.

What you will see change, as I said, is I think you will see filing season response rates — how quickly you can get someone on the phone, how many calls they answer — those will drop. Those metrics will drop. You will see audit rates decline. That is a purposeful thing. The Trump administration has committed to lower audit rates. They think Biden overstepped what the IRS should be doing when he tried to reemphasize audits and enforcement. So you will see those types of changes.

And someday these cuts will catch up to us in just being able to have a functional tax system. And like I said, people have been crying wolf on that for a long time, but it is true. It's just common sense. You can't keep shedding employees, but then asking them to do more. You're doing more economic and finance policy and health policy through the tax code, and you're shrinking the workforce you're asking to implement that. That will catch up to us. And as I said, the first signs we'll probably see is, like I said, a fairly choppy 2026 filing season.

David D. Stewart: Well, let's finish out and talk a little bit more about 2026. It's an even numbered year, so that means elections. What are you looking for in the year ahead?

Jeremy Scott: I mean, if I was going to make a quick prediction, I would say nothing. I imagine nothing will be accomplished in the year ahead. I think they will be lucky to fund the government because there is a January deadline to avoid another shutdown. I think they'll be very focused on that.

There is talk, a lot of talk, about a second reconciliation bill. It's possible you'll see them start to draft one. Maybe they'll put it up for a vote, but the House majority is incredibly slim. And a number of resignations that have taken place have made it even slimmer. It's likely you're going to see the Republicans having 218, 219 members in the House. That's a majority of one to two, and they have trouble holding them all together. And so you need every Republican vote to even put a reconciliation bill into the Senate. And so I find it hard to believe that they will do it.

If they were to do a reconciliation bill, it would likely be a lot of corrections to lingering TCJA issues, some things that they didn't quite get right in OB3. As I said, I think they intended some of these accelerated credits, particularly on the research side, to have a greater impact. They did not realize how they would interact with CAMT. That might be something they put into a reconciliation bill. Some Republicans would like to see more in a second reconciliation bill. Again, with such a narrow majority, I don't see how that's possible.

I think 2026 is going to be dominated by the fight to fund the government and then by the elections. The elections are likely to suck a lot of the oxygen out of the room. And like I said, just doing basic, keep-the-government-open type, business is likely to be difficult, given how House Republicans and House Democrats worked together in 2025, which is to say they did not.

I do not expect a lot of legislation in 2026 beyond just the minimum to keep the government moving. And even that, I think, may prove to be difficult. It would be shocking if we had another shutdown so quickly after the other, but right now looking at it, I don't know how a bill gets through. They probably will find a way. But if you can't even see that type of a bill getting through, I don't think you're likely to see anything that affects tax policy in a large way.

David D. Stewart: Well, it'll be interesting to see how all this plays out. Jeremy, as always, thank you for being here.

Jeremy Scott: Yep. Happy to be here. Thank you.