In the early hours of May 22, the House passed the legislative text of the Republican-led House Ways and Means Committee’s tax proposal, a key component of the anticipated One Big Beautiful Bill, by a narrow 215-214 vote.
Earlier in the week, on May 18, the House Budget Committee approved this legislation, which extends numerous expiring provisions from the 2017 Tax Cuts and Jobs Act (TCJA) and temporarily enhances popular provisions such as the child tax credit and the SALT deduction.
Tax professionals should now prepare for potential changes as the legislation advances to the Senate for further deliberation.
Proposed changes to existing Tax Cuts and Jobs Act provisions under One Big Beautiful Bill
1. Child tax credit (CTC)
Current law: $2,000 per child; expires after 2025
Proposed changes: Temporarily increase the credit to $2,500 per child for tax years 2025-2028, and revert to $2,000 thereafter; full SSN requirements added
2. Estate and gift tax exemption
Current law: increased $13,990,000 exemption (expiring after 2025)
Proposed changes: permanent increase of exemption to $15 million, indexed for inflation
3. §199A pass-through deduction
Current law: 20% deduction based on qualified business income, wages and assets for pass-through entities and sole proprietors
Proposed changes: permanent deduction increased to 23% of the net amount of qualified items of income, gain, deduction and loss from a qualified trade or business
4. SALT deduction cap
Current law: capped at $10,000, expires after 2025
Proposed changes: permanent increase to $40,000 ($20,000 for MFS) subject to phaseout when a taxpayer’s MAGI exceeds $500,000 ($250,000 for MFS); additionally, both the $40,000 SALT cap and the $500,000 income phaseout would increase by 1% per year from 2026 through 2033
Note: The tax legislation, would eliminate the pass-through entity tax (PTET) deduction, which allows eligible pass-through entities to avoid the cap on the state and local tax (SALT) deduction. Instead, specified service trades or businesses (SSTBs) like accountants, dentists, doctors, nurses, veterinarians and lawyers would be subject to the new $40,000 ($20,000 MFS) federal, state and local tax deduction limit.
5. Bonus depreciation
Current law: phases out by Dec. 31, 2026
Proposed changes: extended and restored to 100% immediate deduction for qualified property placed in service after Jan. 19, 2025, and before Dec. 31, 2029; certain property extended through Dec. 31, 2030.
6. R&D expenditures
Current law: expenditures required to be amortized over a five-year period (domestic) for tax years after 2021
Proposed changes: immediate expensing restored for tax years after Dec. 31, 2024, with an election to amortize the expenses over five years; optional ten-year write-off under section §59(e)(2) preserved; effective for research or expenditures made after Dec. 31, 2024, and before Jan. 1, 2030.
New tax provisions included in One Big Beautiful Bill
1. No tax on qualified tip income
The proposed changes include a deduction for qualified tips earned in occupations that customarily receive cash tips. These tips must be reported on specific forms, such as Form W-2, Wage and Tax Statement, or Form 1099-NEC, Nonemployee Compensation.
To qualify, the business must not be classified as a specified trade or business under §199A for the purposes of the qualified business income deduction. Highly compensated individuals, as defined under §414(q)(1), are not eligible for this deduction. This provision is temporary and would apply for tax years 2025 through 2028.
2. No tax on qualified overtime compensation
The proposed changes introduce a deduction for qualified overtime compensation, defined as overtime payments required under Section 7 of the Fair Labor Standards Act (FLSA), calculated as the excess over an employee’s regular rate of pay. This overtime compensation must be reported on Form W-2. The deduction is available as an above-the-line deduction for taxpayers who claim the standard deduction.
However, highly compensated employees are ineligible for this benefit. This provision is temporary and applies for tax years 2025 through 2028.
3. Bonus additional deduction for seniors
The proposed changes provide seniors with a temporary, additional standard deduction of $4,000 instead of exempting Social Security benefits from taxation. This additional deduction phases out for taxpayers with incomes above $75,000 for single filers and $150,000 for married couples filing jointly. The provision is temporary and applies for tax years 2025 through 2028.
4. Car loan interest exclusion
The proposed changes introduce a temporary deduction for interest paid on personal vehicle loans where final assembly occurs in the U.S. This deduction is capped at $10,000 annually and phases out for high-income earners, beginning at $100,000 for single filers and $200,000 for married couples filing jointly. This provision applies temporarily for tax years 2025 through 2028.
Current tax law credits to be repealed under One Big Beautiful Bill
1. Clean vehicle credit (§30D) for vehicles acquired after Dec. 31, 2026. Vehicles purchased in 2026 must meet the manufacturer limits (less than 200,000 vehicles sold).
2. Previously owned clean vehicle credit (§25E), applicable for vehicles acquired after Dec. 31, 2025.
3. Energy efficient home improvement credit (§25C), applicable for property placed in service after Dec. 31, 2025.
4. Residential clean energy credit (§25D), applicable for property placed in service after Dec. 31, 2025.