Craig Carlini, CPA
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Melanie Erickson, CPA merickson@rubino.com

Vikita Shah, EA  vshah@rubino.com

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Final Tax Provisions of “The One, Big, Beautiful Bill Act”

On July 4, 2025, President Trump signed into law the “One Big Beautiful Bill Act” (OBBBA, “the Bill”). The Bill extended many of the expiring tax provisions from the Tax Cuts and Jobs Act of 2017 (TCJA), many of which would otherwise expire after December 31, 2025.

Individual Tax Provisions

Below are select highlights of the individual tax provisions included in the Bill. (Provisions 1-9 below were previously mentioned in our May 2025 newsletter but have been updated with the final provision of the OBBBA).

  1. Enhanced Senior Deduction
    The Bill provides a temporary deduction for seniors (65+) of $6,000 for eligible taxpayers for tax years 2025-2028. Phase out: single filers with income of $75,000 or more (joint filers with income of $150,000 or more).
  2. No Tax on Tips and Overtime Pay
    Tip Deduction: The Bill allows up to a $25,000 deduction per taxpayer for qualified tips for tax years 2025-2028. (Phase out: when the taxpayer’s Modified adjusted gross income (MAGI) exceeds $150,000 ($300,000 in the case of a joint return).
    Overtime Deduction: The Bill provides a temporary deduction of up to $12,500 ($25,000 on joint return) per taxpayer for qualified overtime compensation for tax years 2025-2028. (Phase out: when the taxpayer’s MAGI exceeds $150,000 ($300,000 for a joint return)
  3. Estate and Gift Tax Exemption
    The Bill increased the estate, gift, and the generation-skipping transfer tax exemption to $15 million per individual ($30 million per married couple) in 2026. (indexed for inflation).
  4. Child Tax Credit 
    The Bill raises the credit to $2,200 per child; refundable portion $1,400 for 2025.
  5. State and Local Tax Deduction (SALT) Cap 
    The Bill temporarily raises the SALT deduction cap from $10,000 to $40,000 ($20,000 for married individuals filing separately). Phase-out of the increased SALT deduction cap begins when an individual’s modified adjusted gross income reaches a $500,000 threshold ($250,000 for married individuals filing separately). The cap and phase-out threshold increase incrementally each year, but the cap permanently reverts to $10,000 beginning with the 2030 tax year.
  6. Qualified Business Income Deduction
    The Bill makes the 20% deduction for pass-through income permanent, expands the deduction limit phase-in range, and adds a $400 minimum deduction for those with at least $1,000 of QBI. The 20% qualified business income (QBI) deduction for pass-through entities (including law firms and partnerships) is made permanent. The Bill increases the QBI phase-in threshold for single filers from $50,000 to $75,000 and for joint filers from $100,000 to $150,000, with inflation adjustments applying after 2026.
  7. Eliminate the Clean Vehicle Credit (includes electric vehicles) 
    The Bill terminates a large number of clean energy tax incentives:
    • The clean vehicle credits for both previously owned and new vehicles (Sections 25E and 30D) will end for vehicles purchased after September 30, 2025.
    • The energy-efficient home improvement credit (Section 25C) and the residential clean energy credit (Section 25D) will both expire for qualifying improvements or expenditures made after December 31, 2025. This means that eligible projects must be completed by the end of 2025 to claim these credits.
  8. Tax Deduction for Interest on New Car Loans 
    The Bill makes auto loan interest deductible for taxable years 2025 through 2028 for the purchase of, and that is secured by a first lien on, an applicable passenger vehicle that had their final assembly in the United States, The deduction is limited to $10,000 and is phased out for taxpayers with modified adjusted gross income exceeding $100,000 ($200,000 for a joint return).
  9. An Above-the-Line Deduction for Charitable Contributions 
    The Bill allows non-itemizers to claim a deduction of up to $1,000 for single filers or $2,000 for married taxpayers filing jointly for “cash” charitable contributions beginning in 2025. For itemizers, will only be allowed to claim charitable contributions as deductions to the extent that the aggregate of such contributions exceeds 0.5% of the individual’s adjusted gross income.
  10. Trump Accounts 
    The Bill creates a new tax-deferred savings account, “Trump Accounts,” providing every baby who is a U.S. citizen born between 2025 and before 2029 with a $1,000 federally funded investment account. Tax-favored growth until age 18.
  11. Pass-Through Entity Tax Regimes (PTET) 
    There were no changes or new limitations to the pass-through entity tax (PTET) regimes, i.e., existing PTET/SALT workarounds remain fully available to taxpayers.
  12. Mortgage Interest Deduction
    For tax years beginning after December 31, 2025, the $750,000 principal limit for the home mortgage interest deduction has been made permanent.

Business Tax Provision

Below are select highlights of the business tax provisions included in the Bill.

  1. Bonus Depreciation
    The Bill permanently extends 100% bonus depreciation for property acquired and placed in service on or after January 19, 2025.
  2. Section 179 Expensing
    The Bill increases the Section 179 expensing limit from $1 million to $2.5 million, with the phase-out threshold raised to $4 million.
  3. Research & Development (R&D) Expenses 
    The Bill allows immediate deduction of domestic R&D expenditures for tax years beginning after December 31, 2024. Expenditures for research conducted outside the U.S. must still be capitalized and amortized over 15 years. Small businesses (average annual gross receipts of $31 million or less) may apply this retroactively to tax years after 2021. All taxpayers may elect to accelerate deductions for domestic R&D made after 2021 and before 2025 over one or two years.
  4. Excess Business Losses
    The Bill permanently extends the limitation on excess business losses for noncorporate taxpayers.
  5. Qualified Small Business Stock (QSBS)/Section 1202
    The Bill increases the Sec. 1202 exclusion for gain from qualified small business stock. For qualified small business stock acquired after the date of enactment of the Bill and held for at least four years, the percentage of gain excluded from gross income will rise from 50% to 75%. If it is held for five years or more, the exclusion percentage will go up to 100%.

International Provisions

Below are select highlights of the international tax provisions included in the Bill.

  1. Deemed paid credit
    The Bill amends Sec. 960(d)(1) to increase the deemed paid credit for Subpart F inclusions from 80% to 90%.
  2. GILTI and FDII
    The Bill decreases the Sec. 250 deduction percentage for tax years beginning after Dec. 31, 2025, to 33.34% for foreign-derived intangible income (FDII) and 40% for GILTI, resulting in an effective tax rate of 14% for both FDII and GILTI. The Bill also proposes changing the definition of deduction-eligible income for purposes of determining FDII. The Bill also eliminates the use of a corporation’s deemed tangible income return for determining FDII and the use of net deemed tangible income return in determining GILTI. These changes result in the elimination of the terms FDII and GILTI, which will be renamed “foreign-derived deduction eligible income” and “net CFC tested income,” respectively.

We will continue to provide updates as the legislation’s provisions take effect, final regulations and implementation and/or guidance on navigating these new tax provisions.

This content is for general information purposes only and should not be used as a substitute for consultation with professional advisors. Note that the above updates are subject to change, before making any decision affecting you or your business, please look out for the latest IRS developments