The IRS recently released its 2025-2026 Priority Guidance Plan, which contains several significant retirement, executive compensation, and health and welfare initiatives for this year in connection with the One, Big, Beautiful Bill Act (the “OBBBA”) and the SECURE 2.0 Act, some of which were already published as noted below. For further information regarding the OBBBA and SECURE 2.0 Act, please refer to our prior articles here and here, respectively.
Employers should be aware of the following items on the IRS’s proposed schedule of rulemaking and related guidance:
One, Big, Beautiful Bill Act
- Guidance regarding deductions for qualified tips and overtime compensation, including transition relief.
- Guidance regarding “Trump Accounts,” which are tax-advantaged savings accounts for children under the age of 18.
- Guidance regarding paid family and medical leave credits.
- Regulations under Code Section 162(m) rules regarding excessive employee remuneration from controlled group members and the allocation of the $1,000,000 deduction limit.
- Guidance regarding changes to health savings accounts and high-deductible health plans.
SECURE 2.0 Act
- Guidance implementing several SECURE 2.0 Act provisions including the retirement plan saver’s match, qualified student loan matching contributions, long-term part-time employee eligibility, pension-linked emergency savings accounts, rollover rules, qualified long-term care distributions, and guidance regarding the application of the 10% early distribution rule under Code Section 72(t) relating to repayment provisions for certain distributions.
- Updates to the Employee Plans Compliance Resolution System, addition of a new Compliance Resolution System for Individual Retirement Account (“IRAs”), and guidance on the amendment deadline for IRAs.
- Final regulations related to Required Minimum Distributions. Prior regulations were published on July 19, 2024, as we previously reported here.
- Final regulations and related guidance on the exception to the unified plan rule for multiple employer plans. Proposed regulations were published on March 28, 2022
- Final regulations on automatic enrollment requirements. Proposed regulations were published on January 10, 2025.
- Final regulations on updates to catch-up contribution rules which were published on September 16, 2025, as we previously reported here.
- Guidance on uncashed checks from retirement plans which was published on August 4, 2025, as we previously reported here.
The full IRS 2025-2026 Priority Guidance Plan is available here.
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