One Big Beautiful Bill

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The “One Big Beautiful Bill Act” (H.R.1), signed into law on July 4, 2025, includes a wide array of tax implications for individuals and businesses, largely stemming from the permanent extension and modification of provisions from the 2017 TCJA, alongside new tax relief measures and offsets. Here is an overview of some of the key tax implications that have been signed into law.

1. Individual and Family Tax Provisions:
  • Permanent Lower Individual Tax Rates and Brackets: The bill permanently extends the lower individual income tax rates and brackets established by the TCJA, which were scheduled to expire after 2025. It also provides an extra inflation adjustment to the bottom six brackets, resulting in lower tax bills for many taxpayers.
  • Increased Standard Deduction: The doubled standard deduction from the TCJA is permanently extended. Additionally, an extra inflation adjustment is provided.
  • SALT Deduction Cap: The $10,000 cap on individual itemized deductions for state and local taxes is temporarily increased to $40,000 for tax years 2025 through 2029, with a phase-down for incomes over $500,000.
  • New Deductions for Tipped and Overtime Workers: The bill introduces new provisions allowing workers to deduct income earned from tips and overtime pay, effective through 2028. The benefit for tipped workers is limited to $25,000. The benefit for overtime workers is limited to $12,500 ($25,000 MFJ). Both benefits would phase out when the taxpayer’s modified adjusted gross income exceeds $150,000 ($300,000 for MFJ) and expires in 2028.
  • Additional Deduction for Seniors: Taxpayers over the age of 65 can claim an additional $6,000 deduction per individual (2025-2028); phased out at higher incomes.
  • Mortgage Interest Deduction Cap: The $750,000 cap on the mortgage interest deduction for acquisition debt is made permanent.
  • Mortgage Insurance Deduction: Borrowers can now permanently deduct mortgage insurance premiums (PMI, FHA MIP, VA funding fees, and USDA guarantee fees), subject to income limits.
  • Child Tax Credit (CTC): The bill permanently increases the child tax credit to $2,200 per child, with $1,700 refundable with inflation adjustments.
  • Health Savings Account (HSA) Expansions: The bill expands access to HSAs for patients with high-deductible health plans (HDHPs) and those with bronze and catastrophic-level plans through ACA marketplaces. It also allows HSAs to be used for direct primary care.
  • “Trump Accounts” Establishment: The bill would create a new Sec. 530A, to establish a new type of tax-preferred account. These accounts would be set up for the exclusive benefit of an individual and designated at the time of establishment as such (under rules Treasury will promulgate). The accounts would be exempt from tax. Complete details are still being established. Employer contributions to Trump accounts excluded from income up to $2,500 per employee.
  • Scholarship Tax Credit: A new scholarship tax credit is introduced.
  • Non-Itemizer Charitable Deduction: A deduction for charitable contributions is available even for non-itemizers. The charitable deduction has been added for taxpayers who utilize the standard deduction equal to a $1,000 deduction for single taxpayers and $2,000 for married couples from 2025-2028.
  • Estate and Gift Tax: The bill extends and expands cuts to the estate tax. Increases exemption to $15 million (indexed from 2026); makes higher exemption permanent.
  • No Tax on car loan interest: Allows deduction for up to $10,000 of interest on new car loans (2025–2028); must be US-assembled passenger vehicles with the vehicle serving as security for the loan. Other exceptions apply.
  • 1099 reporting: The threshold for required reporting has increased from $600 to $2,000.
 
2. Business and International Tax Provisions:
Sec.899, also being named as Trump’s “Revenge Tax” was not included in the July 4, 2025 Senate version of the OBBB, it was formally dropped following the G7 meeting in late June 2025.

•     Permanent Business Tax Provisions: Key business tax provisions enacted in the 2017 TCJA that were set to expire are permanently extended. These include:

  • Bonus Depreciation: The bill allows (but does not require) 100% bonus depreciation for qualified property acquired and placed in service on or after January 19, 2025, and before January 1, 2029.
  • Domestic Research & Experimental (R&E) Expenditures: The required capitalization of domestic R&E expenditures is suspended for amounts paid or incurred in taxable years beginning after December 31, 2024, and before January 1, 2030, allowing for immediate expensing. Companies can elect to expense R&D expenditures incurred in the US, capitalize and amortize them over the life of the research (minimum of 60 months), or capitalize and amortize them over 10 years. Foreign R&E expenditure must still be capitalized and amortized over 15 years. The bill provides small businesses with the option to apply this change retroactively back to 2022 through amended returns. It also allows taxpayers to accelerate any remaining Sec. 174 deductions.
  • Business Interest Deduction Limitation (Section 163(j)): For taxable years beginning after December 31, 2024, deduction for new interest expense is limited to 30% of the adjusted taxable income (ATI), the ATI for purposes of the Sec. 163(j) limitation will be computed by reference to EBITDA (including depletion), rather than EBIT. The legislation eliminates the ability for taxpayers to include subpart F and GILTI in their computations for taxable years beginning after December 31, 2025.
  • Section 199A Qualified Business Income (QBI) Deduction: The Section 199A pass-through deduction has been made permanent, with no change to the current 20% deduction percentage. Additionally, the bill expands the limitation phase-in window from $50,000 for single filers ($100,000 for married filing jointly) to $75,000 for single filers ($150,000 for married filing jointly) and creates a minimum deduction of $400 for taxpayers with $1,000 or more of qualified business income (QBI) for material participants.
  • Pass-through Entity Tax: The final law retains full deductibility of state and local taxes paid through state-enacted pass-through entity taxes in over 30 states, a critical win for pass-through businesses.
  • Section 1202: The OBBB modifies the existing 100% exclusion of gain on Qualified Small Business Stock (“QSBS”) stock held at least 5 years and now includes both a 50% exclusion for stock held with at least a 3-year holding period and a 75% exclusion for stock held with at least a 4-year holding period. This provision is effective for QSBS issued after the enactment date. The amount of gain that can be excluded is increased from $10 million to $15 million. The changes to the gross asset threshold apply to QSBS issued after July 4, 2025. The other changes apply to taxable years beginning after July 4, 2025. 
  • FDII and GILTI Section 250 deduction: The OBBB reduces the Section 250 deduction percentage for tax years beginning after December 31, 2025 to 40% for GILTI (prior to OBBB, the deduction was scheduled to be reduced from 50% to 37.5% after December 31, 2025) and 33.34% for FDII (prior to OBBB, the deduction was scheduled to be reduced from 37.5% to 21.875% after December 31, 2025). Additionally, the OBBB eliminates the qualified business asset investment (QBAI) amount from the GILTI and FDII calculations, which is expected to increase the GILTI inclusion amount for most companies while also broadening the scope of companies that may qualify for FDII.
  • BEAT minimum tax on certain related party payments: TCJA introduced BEAT, a minimum tax on international payments. BEAT is imposed when the tax calculated under BEAT exceeds the corporation’s regular tax liability determined after the application of certain credits allowed against the regular tax. BEAT is measured based on modified taxable income (i.e., taxable income after adding back base erosion payments). The OBBB generally adjusts the BEAT rate to 10.5% and also modifies the BEAT calculation. All BEAT-related modifications are effective for taxable years beginning after December 31, 2025.

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