Mindy Herzfeld (Florida), Rationalizing the Post-OBBBA International Tax Rules, Part 2, 120 Tax Notes Int’l 1416 (Dec. 1, 2025)

The second Trump administration’s regulatory priorities for Treasury are twofold: implementation of the One Big Beautiful Bill Act (P.L. 119-21) and deregulation.

The 2025-2026 priority guidance plan issued on September 30 — significantly pared down from prior years’ plans — highlights the shift in priorities and how the current administration wants to use the regulatory process to advance its agenda. But despite ambitious undertakings — implementing new legislation and cleaning up regulatory deadwood — one can also question whether the administration is being ambitious enough in its regulatory efforts, and whether a bolder effort to realign international tax regulations to fit with a post-Tax Cuts and Jobs Act and pillar 2 world is warranted.

The second in a series that considers how U.S. international tax rules might need to be modified to rationalize pre-2017 law with the TCJA, this article considers changes that could be made on the regulatory front. (Prior analysis: Tax Notes Federal, Oct. 20, 2025, p. 419.)