乐鱼（Leyu）体育官网 reports: Tax title for 鈥淥ne Big Beautiful Bill Act鈥�
Analysis and observations on the tax title for the "One Big Beautiful Bill Act"
Introduction
The U.S. House of Representatives on May 22, 2025, passed , the budget reconciliation bill known听as the 鈥淥ne Big Beautiful Bill Act.鈥�
The bill would generally make the tax provisions of the 2017 Tax Cuts听and Jobs Act (TCJA) permanent, such as the lower rates for individuals and for the international provisions global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), and base erosion and anti-abuse tax (BEAT). The bill would also make several important adjustments to current law, including increasing the section 199A deduction for passthrough businesses and would restore for years 2025 through 2029 several expired business tax benefits from the TCJA, including the deductibility of U.S. research and development costs under section 174 and 100% bonus depreciation. The bill would also introduce for years 2025 through 2028 several new tax benefits proposed by the president during the campaign, such as 100% bonus depreciation for new manufacturing facilities and new deductions for tips and overtime pay.
To partially offset the cost of the above taxpayer-favorable changes, the bill includes a host of revenue-raising provisions, including an extension of the existing limit on the individual deduction for state and local taxes (SALT) (but subject to an increased cap), as well as early sunsets, phase outs, and other changes to the energy tax credits enacted in the Inflation Reduction Act (IRA). The bill also provides for retaliatory measures on certain non-U.S. corporations and individuals if their home jurisdiction has adopted taxes deemed to be discriminatory or extraterritorial and would increase tax rates on certain university endowments and private foundations.
The Joint Committee on Taxation (JCT) provided estimated revenue effects of the provisions of H.R. 1 in .听Additionally, the JCT provided a technical explanation () and distribution of the estimated revenue effects () of the tax title as approved by the Ways and Means Committee.
The bill will be transmitted to the Senate for听consideration to begin after the congressional Memorial Day recess. The Senate is expected to make changes to the House-approved bill, possibly听including the tax provisions. 乐鱼（Leyu）体育官网 will continue to provide updates as the bill works its way through the process in Congress.听
乐鱼（Leyu）体育官网 reports: Tax title for 鈥淥ne Big Beautiful Bill Act鈥�
For 乐鱼（Leyu）体育官网 analysis and observations regarding sector or industry-specific provisions in the bill, select a topic of interest below.
Accounting for income taxes implications
Accounting methods
Compensation and benefits
Exempt organizations
Estate and gift
Global mobility and select individual provisions
Incentives and credits
International
Passthroughs
Practice, procedure, and administration
State and local tax implications
Overview and initial observations on the overall tax title
Index of tax title provisions
For ease of reference, provided below is a list of the provisions in H.R. 1 discussed in 乐鱼（Leyu）体育官网鈥檚 sector or industry-specific reports indicating the specific report(s) in which each provision is discussed.
| Section in H.R. 1 | Provision | 乐鱼（Leyu）体育官网 report |
| Sec. 110001 | Extension of modification of rates | |
| Sec. 110002 | Extension of increased standard deduction and temporary enhancement | |
| Sec. 110003 | Termination of deduction for personal exemptions | |
| Sec. 110004 | Extension of increased child tax credit and temporary enhancement | |
| Sec. 110005 | Extension of deduction for qualified business income and permanent enhancement | |
| Sec. 110006 | Extension of increased estate and gift tax exemption amounts and permanent enhancement | |
| Sec. 110007 | Extension of increased alternative minimum tax exemption and modification of the phaseout threshold inflation adjustment | |
| Sec. 110008 | Extension of limitation on deduction for qualified residence interest | |
| Sec. 110009 | Extension of limitation on casualty loss deduction | |
| Sec. 110010 | Termination of miscellaneous itemized deduction | |
| Sec. 110011 | Limitation on tax benefit of itemized deductions | |
| Sec. 110012 | Termination of qualified bicycle commuting reimbursement exclusion | |
| Sec. 110013 | Extension of limitation on exclusion and deduction for moving expenses | |
| Sec. 110101 | No tax on tips | |
| Sec. 110102 | No tax on overtime | |
| Sec. 110106 | Extension and enhancement of paid family and medical leave credit | |
| Sec. 110109 | Scholarship granting organizations | |
| Sec. 110110 | Additional elementary, secondary, and home school expenses treated as qualified higher education expenses for purposes of 529 accounts | |
| Sec. 110111 | Certain post-secondary credentialing expenses treated as qualified higher education expenses for purposes of 529 accounts | |
| Sec. 110112 | Reinstatement of partial deduction for charitable contributions of individuals who do not elect to itemize | |
| Sec. 110113 | Exclusion for certain employer payments of student loans under educational assistance programs made permanent and adjusted for inflation | |
| Sec. 110114 | Extension of rules for treatment of certain disaster-related personal casualty losses | |
| Secs. 110201 鈥� 110213 | Various tax changes relating to health savings accounts | |
| Sec. 111001 | Extension of special depreciation allowance for certain property | |
| Sec. 111002 | Deduction of domestic research and experimental expenditures | |
| Sec. 111003 | Modified calculation of adjusted taxable income for purposes of business interest deduction | |
| Sec. 111004 | Modification of deduction for foreign-derived intangible income and global intangible low-taxed income | |
| Sec. 111005 | Extension and modification of base erosion minimum tax amount | |
| Sec. 111006 | Exception to denial of deduction for business meals听 | Compensation and benefits |
| Sec. 111101 | Special depreciation allowance for qualified production property | |
| Sec. 111102 | Renewal and enhancement of opportunity zones | |
| Sec. 111103 | Increased dollar limitations for expensing of certain depreciable business assets | |
| Sec. 111104 | Repeal of revision to de minimis rules for third party network transactions | |
| Sec. 111105 | Increase in threshold for requiring information reporting with respect to certain payees | |
| Sec. 111107 | Treatment of certain qualified sound recording productions | |
| Sec. 111108 | Modifications to low-income housing credit | Incentives and credits |
| Sec. 111109 | Increased gross receipts threshold for small manufacturing businesses | |
| Sec. 111110 | Global intangible low-taxed income determined without regard to certain income derived from services performed in the Virgin Islands | |
| Sec. 111111 | Extension and modification of clean fuel production credit | |
| Sec. 111112 | Restoration of taxable REIT subsidiary asset test | |
| Sec. 112001 | Termination of previously owned clean vehicle credit | |
| Sec. 112002 | Termination of clean vehicle credit | |
| Sec. 112003 | Termination of qualified commercial clean vehicles credit | |
| Sec. 112004 | Termination of alternative fuel vehicle refueling property credit | |
| Sec. 112005 | Termination of energy efficient home improvement credit | |
| Sec. 112006 | Termination of residential clean energy credit | |
| Sec. 112007 | Termination of new energy efficient home credit | |
| Sec. 112008 | Restrictions on clean electricity production credit | |
| Sec. 112009 | Restrictions on clean electricity investment credit | |
| Sec. 112010 | Repeal of transferability of clean fuel production credit | |
| Sec. 112011 | Restrictions on carbon oxide sequestration credit | |
| Sec. 112012 | Restrictions on zero emission nuclear power production credit | |
| Sec. 112013 | Termination of clean hydrogen production credit | |
| Sec. 112014 | Phase-out and restrictions on advanced manufacturing production credit | |
| Sec. 112015 | Phase-out of credit for certain energy property | |
| Sec. 112016 | Income from hydrogen storage, carbon capture added to qualifying income of certain publicly traded partnerships treated as corporations | Incentives and credits听/听Passthroughs |
| Sec. 112017 | Limitation on amortization of certain sports franchises | |
| Sec. 112018 | Limitation on individual deductions for certain state and local taxes | |
| Sec. 112019 | Excessive employee remuneration from controlled group members and allocation of deduction | |
| Sec. 112020 | Expanding application of tax on excess compensation within tax-exempt organizations | |
| Sec. 112021 | Modification of excise tax on investment income of certain private colleges and universities | |
| Sec. 112022 | Increase in rate of tax on net investment income of certain private foundations | |
| Sec. 112023 | Certain purchases of employee-owned stock disregarded for purposes of foundation tax on excess business holdings | |
| Sec. 112024 | Unrelated business taxable income increased by amount of certain fringe benefit expenses for which deduction is disallowed | |
| Sec. 112025 | Exclusion of research income limited to publicly available research | |
| Sec. 112026 | Limitation on excess business losses of noncorporate taxpayers | |
| Sec. 112027 | 1-percent floor on deduction of charitable contributions made by corporations | |
| Sec. 112028 | Enforcement of remedies against unfair foreign taxes | |
| Sec. 112029 | Remove silencers from the National Firearms Act 听 | |
| Sec. 112032 | Treatment of payments from partnerships to partners for property or services | |
| Sec. 112104 | Excise tax on remittance transfers | |
| Sec. 112205 | Enforcement provisions with respect to COVID-related employee retention credits | |
| Sec. 112207 | Task force on the termination of Direct File | |
| Sec. 112208 | Increase in penalties for unauthorized disclosures of taxpayer information | |
| Sec. 112209 | Restriction on regulation of contingency fees with respect to tax returns, etc. |
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