
NAEA Offers OBBBA Implementation Assistance
In a September 10 letter to Treasury, NAEA urged clear, timely rules for the One Big Beautiful Bill Act (OBBBA). The message echoed across Bloomberg Tax and on Talking Tax podcast, where NAEA President Jennifer MacMillan, EA, outlined what tax pros need for a smooth filing season.
What NAEA Asked Treasury to Do
In the letter addressed to Treasury Assistant Secretary for Tax Policy Ken Kies on September 10, NAEA President Jennifer MacMillan offered the association’s assistance on implementing OBBBA and developing related forms and guidance.
“Our organization is uniquely positioned to offer a practical perspective on tax administration. NAEA has long advocated for creating an efficient, transparent, and taxpayer-centered tax administration system that provides clear rules for the benefit of both tax professionals and taxpayers,” MacMillan said.
For the 2025–2028 temporary OBBBA provisions, NAEA recommended:
- No Taxes on Qualified Tips: Having robust guidance on the transition relief being provided for 2025, and clear definitions of what constitutes qualifying tips.
- No Taxes on Overtime Compensation: Having guidance on the transition relief being provided for 2025 as early as before the 4th quarter payroll reporting deadline to ensure the greatest efficiency and compliance.
- Deductions on Car Loan Interest: Ensuring correct information related to the car loan interest deduction is obtained will be essential to compliance. EAs are interested in whether all auto loan interest payments will be reported and left to taxpayers and tax professionals to determine if the interest is qualified. NAEA believes there is an opportunity within any new form, after consultation with the private sector, for the IRS to build in tax software that would be able to reject ineligible VINs to prevent errors.
“In our experience, a strong partnership between the IRS and tax professionals, particularly when implementing complex laws, leads to stronger and more precise guidance,” MacMillan stated.
In the News
Zach C. Cohen featured NAEA’s call for clarity in the Bloomberg Government Tax newsletter on Sept. 12, 2025 (paywalled), underscoring practitioners’ push for swift guidance on Trump’s tax breaks.
NAEA President Jennifer MacMillan, EA, joined Bloomberg Tax’s Erin Slowey on the latest episode of the Talking Tax podcast to discuss what tax professionals should expect this filing season. Topics include proposed minimum standards for tax preparers, taxation of tips, contingency fees, and other policy and practice issues top of mind for tax professionals and their clients.
Listen: “Enrolled Agents Anticipate IRS Chaos for Next Tax Filing Season”
Why This Matters
The National Association of Enrolled Agents (NAEA) is the professional association for enrolled agents (EAs), federally licensed tax practitioners authorized to represent taxpayers before the IRS. Approximately 65,000 EAs nationwide serve millions of taxpayers each year. Clear, timely rules and well-designed reporting mechanisms are central to effective tax administration, especially when new laws take effect.
- Speed + certainty: Early, clear guidance lowers burden on practitioners and taxpayers and improves return accuracy.
- Better compliance by design: Smart reporting and validation can prevent ineligible claims upstream.
- Alignment with the field: Incorporating feedback from EAs—the professionals filing and advising daily—helps Treasury and IRS deliver workable rules the first time.



