A second budget reconciliation bill to follow last summer's One Big Beautiful Bill Act (OBBBA) is getting another look in Congress, with certain Republican senators this week outlining a plan to use the reconciliation process to enact Immigration and Customs Enforcement (ICE) provisions. This would be separate from the Homeland Security funding bill.

The focus of the reconciliation effort would be the ICE provisions and portions of the SAVE America Act voter ID bill, although it is unclear if the latter could pass muster under reconciliation rules. There also could be efforts to attach some of the Pentagon's requested $200b war supplemental and perhaps other Republican priorities.

Senate Majority Leader John Thune (R-SD) was quoted as saying, "If we end up going down that route [budget reconciliation], we'll try and make the most of the opportunity."

Also this week, there was some movement on the Senate's stalled crypto bill. Senate Banking Committee members Thom Tillis (R-NC) and Angela Alsobrooks (D-MD) and the White House agreed on language aimed at resolving a dispute between banks and the digital asset industry. Senator Cynthia Lummis (R-WY), a crypto specialist on the Banking Committee, said the breakthrough could finally allow a markup of the digital market structure bill in April after the Senate's recess.

In Notice 2026-23, the IRS solicited recommendations for the 2026–2027 Priority Guidance Plan. The IRS is requesting that recommendations for this guidance plan be submitted by 29 May 2026, although taxpayers may submit suggestions at any time during the year.

And the IRS reportedly is questioning whether it should extend the passive foreign investment company/controlled foreign corporation (PFIC/CFC) overlap rule under IRC Section 1297(d) to the two new classifications of foreign companies in IRC Section 951B. A senior IRS official said, "it's a big question, should we extend the overlap rule to these foreign-controlled foreign corporations to turn off PFIC treatment or PFIC status with respect to certain US shareholders or foreign-controlled US shareholders?"