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Senate Passes One Big Beautiful Bill Including Pass Through Entity Relief
Senate Passes One Big Beautiful Bill Including Pass Through Entity Relief

Forbes

time01-07-2025

  • Business
  • Forbes

Senate Passes One Big Beautiful Bill Including Pass Through Entity Relief

The Senate passed their amended version of the One Big Beautiful Bill today, in a vote of 50-50 with Vice President Vance casting the tie-breaking vote. Republican Senators Rand Paul, Susan Collins, and Thom Tills voted no. The bill must now be passed by the House of Representatives, where only three Republican votes can be lost. WASHINGTON, DC - JULY 1: (EDITOR'S NOTE: Alternative Crop) Senate Majority Leader John Thune (R-SD) ... More (C), accompanied by Sen. John Barrasso (R-WY) (L) and Sen. Mike Crapo (R-ID) (R), speaks to reporters off the Senate floor after the Senate passes President Donald Trump's so-called "One, Big, Beautiful Bill," Act at the U.S. Capitol Building on July 1, 2025 in Washington, DC. U.S. Vice President J.D. Vance was the tie-breaking vote as President Donald Trump's so-called "One, Big, Beautiful Bill," Act passes in the Senate. (Photo by) House leadership has indicated that they will vote on the bill tomorrow. If the House passes the Senate version, it will go to the President for his signature. If the House makes any changes to the bill, it will have to go back to the Senate for approval. While both the House and Senate bills proposed language that was extremely harmful to the pass-through entity community, the final Senate bill passed made significant modifications that will encourage continued investments via pass through entities. Pass Through Entity Tax (PTET) Payments: While both the House and the original Senate bill limited PTET deductions, no such language was included in the final bill passed by the Senate. In the original bill, the Senate has limited PTET payments to the greater of $40,000 or 50% of the PTET payment made. The removal of the language in the final Senate bill is a welcome relief, confirming that entity type should not dictate whether state and local taxes are deductible. The Senate bill, similar to the House bill, increases the individual state and local tax (SALT) cap from $10,000 to $40,000 staring in 2025. However, the SALT cap would be reduced for taxpayers with modified AGI over $500,000, but the overall SALT deduction cannot go below $10,000 ($5,000 for MFS). If a married filing joint taxpayers modified AGI exceeds $600,000, the SALT cap would be $10,000. Under the Senate bill passed, PTET deductions do not fall under the SALT cap, and would be fully deductible. Excess Business Loss (EBL) Provision: Both the House and the original Senate bill required that any EBL limitations be carried forward to the following year, and again included in the excess business loss limitation calculation. This is different from the current law, that allows for any excess business loss to be considered a net operating loss, and carried forward for use in future years. The original proposals essentially limited individual taxpayers and only allowed EBL carryforwards to be utilized on trade or business income. The bill passed by the Senate makes the EBL provisions permanent, but does not require the EBL to be carried forward in the EBL calculation for the following year. Instead, the bill would allow for the current law to remain and an EBL to be characterized as a net operating loss. The net operating losses can offset future year up to 80% of total taxable income in future years. Section 199A: The final Senate bill makes permanent the 199A deduction, and provides for a 20% deduction for taxable years beginning after December 31, 2025. The House bill provided for an increase in the 199A deduction to 23%. The 199A deduction is eventually phased out for specified service trades or businesses (SSTBs) when an owner's taxable income exceeds a certain threshold amount. Trades or businesses that are subject to this phase-out include businesses involving the performance of services in the fields of health, law, accounting, actuarial science, performing arts, consulting, athletics or financial services. Current law starts to phase-out a SSTB's 199A deduction when taxable income exceeds $100,000 for married filing joint taxpayers ($50,000 for all others). The Senate bill would increase the threshold amount to $150,000 for married filing joint taxpayers ($75,000 for all others). In addition, the Senate bill provides for a $400 minimum 199A deduction if a taxpayer materially participates in a qualified trade or business and has income of at least $1,000. The Senate bill would enact these changes for taxable year beginning after December 31, 2025.

The Senate's $40,000 SALT Deduction Signals Tax Relief For Homeowners
The Senate's $40,000 SALT Deduction Signals Tax Relief For Homeowners

Forbes

time01-07-2025

  • Business
  • Forbes

The Senate's $40,000 SALT Deduction Signals Tax Relief For Homeowners

Hands count dollars to buy a new house The Senate has narrowly passed the One Big Beautiful Bill Act by a 50-50 vote, with Vice President Vance breaking the tie. The bill now moves to the Joint Conference Committee for reconciliation of differences. However, one expected difference between the House and Senate versions of the bill —the State and Local Tax (SALT) deduction — appears to have already been rectified. While the SALT deduction can be used for any state and local income taxes paid, the taxes paid on a home tend to be among the largest for taxpayers, suggesting this higher cap will be a welcome relief for home owners. This article discusses the SALT deduction and what this reconciliation means, assuming the One Big Beautiful Bill Act is ultimately signed into law. SALT Deductions Before The Tax Cuts And Jobs Act of 2017 Before the Tax Cuts and Jobs Act of 2017, the SALT deduction allowed taxpayers to claim unlimited itemized deductions for taxes paid to state and local governments. For instance, if the taxpayer paid $20,000 in taxes on their home during the year, they could then deduct the $20,000 from their income, thereby lowering their tax liability. Many taxpayers were limited on how much they could actually deduct due to complex alternative minimum tax rules that existed before 2017, as outlined by the Tax Foundation. However, the benefits were still very much present. SALT Deductions After The Tax Cuts And Jobs Act of 2017 The Tax Cuts and Jobs Act of 2017 modified Section 164 of the Internal Revenue Code in two key ways, limiting the financial benefit of the SALT deduction. First, it capped the deduction at $10,000. This limit means that whether the taxpayer paid $10,000 or $100,000 in SALT, the deduction the taxpayer could take would only be $10,000. Second, the Tax Cuts and Jobs Act increased the standard deduction from $13,000 in 2016 for married taxpayers to $24,000 in 2017. The combination of taxpayers having lower SALT deductions and a higher standard deduction resulted in far fewer taxpayers itemizing their taxes and utilizing the SALT deduction to their advantage. To illustrate the impacts, consider two different married taxpayers. The first has $15,000 in SALT paid and no other itemized deductions. For this taxpayer, the onset of the Tax Cuts and Jobs Act represented a significant win, as they went from having $15,000 in itemized deductions to a $24,000 standard deduction. Assuming the taxpayer was at the 32% tax bracket, the extra $9,000 in deductions increased their after-tax income by $2,880. Now consider the second taxpayer, who has $50,000 in SALT deductions before 2017. If these deductions were now capped at $10,000 and they had no other itemized deductions, they would go from $50,000 in deductions to a $24,000 standard deduction. Assuming the same 32% tax bracket, the $26,000 in lost deductions increased their tax liability by $8,320. The One Big Beautiful Bill Act And A Larger SALT Tax Deduction A key issue with the $10,000 SALT deduction cap was that it asymmetrically impacted taxpayers in higher-cost-of-living locations versus others. For instance, consider a taxpayer in New York City, which has some of the most expensive real estate in the world. That taxpayer is paying more in taxes on their home than a taxpayer in other major cities (such as Chicago, Houston, and Philadelphia), medium-sized cities (like Charlotte, Kansas City, and Denver), or even more rural areas for a similarly sized home. However, they all have the same cap on their SALT deductions. This notion has led many members of Congress to request that the SALT deduction cap be increased in the One Big Beautiful Bill Act. As I previously reported in Forbes, the House included a $40,000 deduction cap in its version of the bill, and this cap would increase annually to help offset the rising costs. However, the Senate introduced a version of the bill that would maintain a cap of $10,000. As I reported in a separate Forbesarticle, this was going to be a big sticking point during the Joint Conference Committee as the two sides appeared to be at odds with one another. However, in a surprising turn, the difference is no longer present. In the Senate's passage of the bill, they have agreed to raise the SALT deduction cap to $40,000, as reported by CNBC. Their version of the bill also allows for an annual increase in the deduction. Both versions also agree that the cap would begin to phase out among taxpayers who earn over $500,000 in income, meaning that ultrahigh earners would still be able to deduct only $10,000. In considering the two taxpayers from earlier, the first (which had $50,000 in SALT paid) would now be able to itemize their taxes again, utilizing the higher SALT deduction limit. The second (which had $15,000 in SALT paid) would continue benefiting from the higher standard deduction. Two Key Differences On The SALT Deduction To Be Resolved While it appears as though the two versions have converged, there are two key differences: (1) Expiration Date The Senate's version increases the SALT deduction cap for the years 2025 through 2028. In 2029 it will revert back to $10,000, at which time, Congress will need to decide to reenact the higher tax deduction. The House's version would extend several additional years through 2033. (2) Alternative Minimum Tax Rules The House's version of the bill includes provisions to limit tax deductions for ultrahigh earners, often referred to as the alternative minimum tax. The Senate version has a more taxpayer-friendly alternative minimum tax. The Committee for a Responsible Federal Budget estimates that this difference makes the Senate version of the bill 67% more taxpayer-friendly than the House version, as the Senate version will result in $325 billion in additional tax outflows for the Federal government. In contrast, the House version will only result in $200 billion in additional tax outflows. While these differences can and will be addressed in the Joint Conference Committee, it is essential to note that the primary details appear to have been resolved. As the US taxpayers look forward to the prospects of the One Big Beautiful Bill Act being signed into law on the 4th of July, the most recent revelation and agreement between the two chambers of Congress should be a welcome sign for homeowners seeking to make better use of their SALT deductions this coming tax season.

GOP leader sets Saturday vote on Trump ‘big, beautiful bill' despite Republican pushback
GOP leader sets Saturday vote on Trump ‘big, beautiful bill' despite Republican pushback

Yahoo

time28-06-2025

  • Business
  • Yahoo

GOP leader sets Saturday vote on Trump ‘big, beautiful bill' despite Republican pushback

Senate Majority Leader John Thune (R-S.D.) told Senate Republicans to expect to see the legislative text of the budget reconciliation package on Friday evening and then to vote at noon Saturday to begin debate on President Trump's tax and spending bill. Thune gave GOP senators the updated schedule after they met with Treasury Secretary Scott Bessent to discuss a tentative deal between the White House and House Republicans from New York, New Jersey and California to raise the cap on state and local tax (SALT) deductions from $10,000 to $40,000 for a period of five years. But Thune acknowledged after the meeting that the schedule could slip, calling the Saturday vote 'aspirational.' 'All of it depends on we got a few things we're waiting on, outcomes from the parliamentarian. If we can get some of those questions, issues landed then my expectation is at some point, yeah, tomorrow we'll be ready to go,' Thune told reporters. 'I said, again, aspirationally, that we'd try to do it at some point in the middle of the day,' he said of the plan to vote Saturday to proceed to the bill. Senate Republicans control a 53-seat majority and can afford three GOP defections on the bill and still pass it with a tiebreaking vote from Vice President Vance. Several GOP senators, however, refused to say whether they would vote to proceed to the bill, including Sens. Bill Cassidy (La.), Lisa Murkowski (Alaska) and Ron Johnson (Wis.). 'I don't know what we're voting on,' Cassidy told reporters when asked whether he would vote for the motion to proceed to the bill. Murkowski said, 'We have not seen text. I don't have anything more to say other than that.' Hundreds of billions of dollars in cuts to Medicare spending are a major problem for several Republican senators, including Murkowski and Sens. Susan Collins (Maine), Josh Hawley (Mo.) and Jerry Moran (Kan.). Johnson appeared angry over the decision to forge ahead with a vote, despite his pleas to spend more time on finding additional spending cuts. 'We'll see,' he said when asked about whether he would vote to move forward. He said before the lunch meeting that the Senate is 'not ready' to begin voting on the bill this weekend. 'We're just not ready for it, I hope that they don't do that,' he said. Sen. Thom Tillis (R-N.C.) told reporters after the lunch that he's not ready to vote to move forward on the bill unless he sees substantial changes to it. Sen. Rand Paul (R-Ky.) says he's a hard 'no' on the legislation because it includes a provision to raise the debt limit by $5 trillion. 'Some people want to spend more money, some people want to spend less money. And so they're pulling. I don't know if it rips. If they keep going in the current direction, they could rip it apart,' he said. 'I think it eventually is going to be much more of a spending bill than a bill that rectifies the debt problem.' Copyright 2025 Nexstar Media, Inc. All rights reserved. This material may not be published, broadcast, rewritten, or redistributed.

Live updates: Iran considers closing Strait of Hormuz
Live updates: Iran considers closing Strait of Hormuz

Yahoo

time22-06-2025

  • Politics
  • Yahoo

Live updates: Iran considers closing Strait of Hormuz

Trump administration officials on Sunday sought to contain the response to U.S. strikes on Iran a day earlier, saying they administration would not let Iran become a nuclear power but was not looking for a wider war or regime change in that country. Defense Sec. Pete Hegseth in comments Sunday morning said now was the time for peace and that the U.S. did not want regime change, while Vice President Vance said the U.S. was at war with Iran's nuclear program and not the country. A big question going forward is how Iran will react, and whether it seeks to de-escalate tensions after the serious U.S. military strikes. Iranian television on Sunday reported that country's parliament had approved a measure to close the Strait of Hormuz, a key shipping route that could have serious implications for both the global and U.S. economy. The strait lies between Iran and Oman. A final decision on closing the route, the Iranian television report said, would rest with Iran's Supreme National Security Council. U.S. bombs targeted three nuclear sites in Natanz, Esfahan and Fordow, located inside a mountain. Six 'bunker buster' bombs were reportedly dropped on Fordow, while more than two dozen Tomahawk missiles were launched at the other two sites. The administration has argued the strikes were a monumental success, but at this early stage it is unclear how much the sites were damaged or how long it has set back Iran's nuclear program. Trump on Saturday night and U.S. officials on Sunday made it clear further strikes were on the table based on Iran's next steps. Follow along here for the latest on these stories and more. Get updated: 5 takeaways as US joins war with Iran Trump warns of more attacks if Iran does not move toward peace Follow along here today for reaction and updates on the conflict. Copyright 2025 Nexstar Media, Inc. All rights reserved. This material may not be published, broadcast, rewritten, or redistributed.

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