Comment from Kallina, Emanuel
Emanuel KallinaSupportAdvocacy
Summary: The American College of Trust and Estate Counsel (ACTEC) is requesting that the IRS and Treasury include specific interpretive issues regarding the new Section 68 limitations in the 2026-2027 Priority Guidance Plan. They argue that the current language creates significant ambiguity regarding its application to trusts, estates, and specific deductions like those under Sections 651, 661, and 642(c).
2026-2027 Priority Guidance Plan Comments Regarding IRC Section 68 - Overall Limitation on Itemized Deductions as amended by the One Big Beautiful Bill Act