Tax Pros Hope Terse New Guidance Projects Reduce Burdens

An aerial photograph showcasing the tightly packed urban landscape of a cityAn aerial photograph showcasing the tightly packed urban landscape of a city

Tax Pros Hope Terse New Guidance Projects Reduce Burdens

October 27, 2025

United States
United States
United States
Tax Notes Federal

Eversheds Sutherland attorneys Ellen McElroy and Michael Resnick are quoted in Tax Notes Federal discussing the IRS and Treasury’s 2025–2026 priority guidance plan, which includes two projects aimed at simplifying regulations under sections 263A and 451.

Ellen emphasized the administration’s goal of reducing taxpayer compliance burdens, while Michael noted the challenge of completing the guidance plan amid a government shutdown. The article highlights potential revisions to the cost offset method under section 451(b), which Ellen described as burdensome due to its item-by-item application. Michael pointed to opportunities for simplification in UNICAP rules under section 263A, including automatic method changes and increased de minimis thresholds.

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Key contacts

ellenmcelroy@eversheds-sutherland.com

Ellen McElroy

Partner

Washington, DC, United States

michaelresnick@eversheds-sutherland.com

Michael D. Resnick

Counsel

Washington, DC, United States

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