One Big Beautiful Bill Act: what this law changes in taxes
This law amends federal tax law in 321 places, in 108 sections of the law.
Income tax, individuals and businesses: each provision, in the law’s order
Each provision below is one sentence of the law that says a part of a federal tax law is amended or repealed. The words are the law’s own. The tax type comes from the number of the Code section the sentence names.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 56(b)(2) of the Internal Revenue Code of 1986.
“Section 56(b)(2) is amended-- (A) in subparagraph (A)-- (i) by striking ``or 174(a)'' in the matter preceding clause (i) and inserting ``, 174(a), or 174A(a)'', and (ii) by striking ``research and experimental expenditures described in section 174(a)'' in clause (ii) thereof and inserting ``foreign research or experimental expenditures described in section 174(a) and domestic research or experimental expenditures in section 174A(a)'', and (B) in subparagraph (C), by inserting ``or 174A(a)'' after ``174(a)''. (4) Optional 10-year writeoff.--”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 59(e)(2)(B) of the Internal Revenue Code of 1986.
“Section 59(e)(2)(B) is amended by striking ``section 174(a) (relating to research and experimental expenditures)'' and inserting ``section 174A(a) (relating to domestic research or experimental expenditures)''. (5) Qualified small issue bonds.--”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 144(a)(4)(C)(iv) of the Internal Revenue Code of 1986.
“Section 144(a)(4)(C)(iv) is amended by striking ``174(a)'' and inserting ``174A(a)''. (6) Start-up expenditures.--”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 195(c)(1) of the Internal Revenue Code of 1986.
“Section 195(c)(1) is amended by striking ``or 174'' in the last sentence and inserting ``174, or 174A''. (7) Capital expenditures.-- (A)”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 263(a)(1)(B) of the Internal Revenue Code of 1986.
“Section 263(a)(1)(B) is amended by inserting ``or 174A'' after ``174''. (B)”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 263A(c)(2) of the Internal Revenue Code of 1986.
“Section 263A(c)(2) is amended by inserting ``or 174A'' after ``174''. (8) Active business computer software royalties.--”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 864(g)(2) of the Internal Revenue Code of 1986.
“Section 864(g)(2) is amended-- (A) by striking ``research and experimental expenditures within the meaning of section 174'' in the first sentence and inserting ``foreign research or experimental expenditures within the meaning of section 174 or domestic research or experimental expenditures within the meaning of section 174A'', and (B) in the last sentence-- (i) by striking ``treated as deferred expenses under subsection (b) of section 174'' and inserting ``allowed as an amortization deduction under section 174(a) or section 174A(c),'', and (ii) by striking ``such subsection'' and inserting ``such section (as the case may be)''. (10) Basis adjustment.--”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 1016(a)(14) of the Internal Revenue Code of 1986.
“Section 1016(a)(14) is amended by striking ``deductions as deferred expenses under section 174(b)(1) (relating to research and experimental expenditures)'' and inserting ``deductions under section 174 or 174A(c)''. (11) Small business stock.--”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70302: FULL EXPENSING OF DOMESTIC RESEARCH AND EXPERIMENTAL EXPENDITURES (b)Income tax, individuals and businesses
Amends section 1202(e)(2)(B) of the Internal Revenue Code of 1986.
“Section 1202(e)(2)(B) is amended by striking ``which may be treated as research and experimental expenditures under section 174'' and inserting ``which are treated as foreign research or experimental expenditures under section 174 or domestic research or experimental expenditures under section 174A''.”
Effective date, in the law’s words (subsection (e)): “(1) In general.--Except as otherwise provided in this subsection or subsection (f)(1), the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after December 31, 2024.” The quote stops here.
- Title VII, Subtitle A, Section 70303: MODIFICATION OF LIMITATION ON BUSINESS INTEREST (a)Income tax, individuals and businesses
Amends section 163(j)(8)(A)(v) of the Internal Revenue Code of 1986.
“Section 163(j)(8)(A)(v) is amended by striking ``in the case of taxable years beginning before January 1, 2022,''.”
Effective date, in the law’s words (subsection (c)): “(1) In general.--The amendments made by this section shall apply to taxable years beginning after December 31, 2024. (2) Special rule for short taxable years.--The Secretary of the Treasury (or the Secretary's delegate) may prescribe such rules as are necessary or appropriate to provide for the application of the amendments made by this section in the case of any taxable year of less than 12 months that begins after” The quote stops here.
- Title VII, Subtitle A, Section 70303: MODIFICATION OF LIMITATION ON BUSINESS INTEREST (b)Income tax, individuals and businesses
Amends section 163(j)(9)(C) of the Internal Revenue Code of 1986.
“Section 163(j)(9)(C) is amended by adding at the end the following new flush sentence: ``Such term shall also include any trailer or camper which is designed to provide temporary living quarters for recreational, camping, or seasonal use and is designed to be towed by, or affixed to, a motor vehicle.''.”
Effective date, in the law’s words (subsection (c)): “(1) In general.--The amendments made by this section shall apply to taxable years beginning after December 31, 2024. (2) Special rule for short taxable years.--The Secretary of the Treasury (or the Secretary's delegate) may prescribe such rules as are necessary or appropriate to provide for the application of the amendments made by this section in the case of any taxable year of less than 12 months that begins after” The quote stops here.
- Title VII, Subtitle A, Section 70304: EXTENSION AND ENHANCEMENT OF PAID FAMILY AND MEDICAL LEAVE CREDIT (a)Income tax, individuals and businesses
Amends section 45S of the Internal Revenue Code of 1986.
“Section 45S is amended-- (1) in subsection (a)-- (A) by striking paragraph (1) and inserting the following: ``(1) In general.--For purposes of section 38, in the case of an eligible employer, the paid family and medical leave credit is an amount equal to either of the following (as elected by such employer): ``(A) The applicable percentage of the amount of wages paid to qualifying employees with respect to any period in which such employees are on family and medical leave.”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70304: EXTENSION AND ENHANCEMENT OF PAID FAMILY AND MEDICAL LEAVE CREDIT (b)Income tax, individuals and businesses
Amends section 280C(a) of the Internal Revenue Code of 1986.
“Section 280C(a) is amended-- (1) by striking ``45S(a)'' and inserting ``45S(a)(1)(A)'', and (2) by inserting after the first sentence the following: ``No deduction shall be allowed for that portion of the premiums paid or incurred for the taxable year which is equal to that portion of the paid family and medical leave credit which is determined for the taxable year under section 45S(a)(1)(B).''.”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70305: EXCEPTIONS FROM LIMITATIONS ON DEDUCTION FOR BUSINESS MEALS (a)Income tax, individuals and businesses
Amends section 274(o) of the Internal Revenue Code of 1986.
“Section 274(o), as added by section 13304 of Public Law 115-97, is amended by striking ``No deduction'' and inserting ``Except in the case of an expense described in subsection (e)(8) or (n)(2)(C), no deduction''.”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to amounts paid or incurred after December 31, 2025.”
- Title VII, Subtitle A, Section 70305: EXCEPTIONS FROM LIMITATIONS ON DEDUCTION FOR BUSINESS MEALS (b)Income tax, individuals and businesses
Amends section 274(n)(2)(C) of the Internal Revenue Code of 1986.
“Section 274(n)(2)(C) of the Internal Revenue Code of 1986 is amended by striking ``or'' at the end of clause (iii) and by adding at the end the following new clause: ``(v) provided-- ``(I) on a fishing vessel, fish processing vessel, or fish tender vessel (as such terms are defined in section 2101 of title 46, United States Code), or ``(II) at a facility for the processing of fish for commercial use or consumption which-- ``(aa) is located in the United States north of 50 degrees north latitude, and ``(bb) is not located in a metropolitan statistical area (within the meaning of section 143(k)(2)(B)), or''.”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to amounts paid or incurred after December 31, 2025.”
- Title VII, Subtitle A, Section 70306: INCREASED DOLLAR LIMITATIONS FOR EXPENSING OF CERTAIN DEPRECIABLE BUSINESS ASSETS (a)Income tax, individuals and businesses
Amends section 179(b) of the Internal Revenue Code of 1986.
Old New $1,000,000 $2,500,000 $2,500,000 $4,000,000 “Section 179(b) is amended-- (1) in paragraph (1), by striking ``$1,000,000'' and inserting ``$2,500,000'', and (2) in paragraph (2), by striking ``$2,500,000'' and inserting ``$4,000,000''.”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to property placed in service in taxable years beginning after December 31, 2024.”
- Title VII, Subtitle A, Section 70307: SPECIAL DEPRECIATION ALLOWANCE FOR QUALIFIED PRODUCTION PROPERTY (a)Income tax, individuals and businesses
Amends section 168 of the Internal Revenue Code of 1986.
“Section 168 is amended by adding at the end the following new subsection: ``(n) Special Allowance for Qualified Production Property.-- ``(1) In general.--In the case of any qualified production property of a taxpayer making an election under this subsection-- ``(A) the depreciation deduction provided by section 167(a) for the taxable year in which such property is placed in service shall include an allowance equal to 100 percent of the adjusted basis of the qualified production property, and ``(B) the adjusted basis of the qualified production property shall be reduced by the amount of such deduction before computing the amount otherwise allowable as a depreciation deduction under this”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to property placed in service after the date of the enactment of this Act.”
- Title VII, Subtitle A, Section 70307: SPECIAL DEPRECIATION ALLOWANCE FOR QUALIFIED PRODUCTION PROPERTY (b)Income tax, individuals and businesses
Amends section 1245(a)(3) of the Internal Revenue Code of 1986.
“Section 1245(a)(3) is amended by striking ``or'' at the end of subparagraph (E), by striking the period at the end of subparagraph (F) and inserting ``, or'', and by adding at the end the following new subparagraph: ``(G) any qualified production property (as defined in section 168(n)(2)).''.”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to property placed in service after the date of the enactment of this Act.”
- Title VII, Subtitle A, Section 70308: ENHANCEMENT OF ADVANCED MANUFACTURING INVESTMENT CREDIT (a)Income tax, individuals and businesses
Amends section 48D(a) of the Internal Revenue Code of 1986.
Old New 25 percent 35 percent “Section 48D(a) is amended by striking ``25 percent'' and inserting ``35 percent''.”
Effective date, in the law’s words (subsection (b)): “The amendments made by this section shall apply to property placed in service after December 31, 2025.”
- Title VII, Subtitle A, Section 70309: SPACEPORTS ARE TREATED LIKE AIRPORTS UNDER EXEMPT FACILITY BOND RULES (a)Income tax, individuals and businesses
Amends section 142(a)(1) of the Internal Revenue Code of 1986.
“Section 142(a)(1) is amended to read as follows: ``(1) airports and spaceports,''.”
Effective date, in the law’s words (subsection (f)): “The amendments made by this section shall apply to obligations issued after the date of the enactment of this Act. Subchapter B--Permanent America-first International Tax Reforms PART I--FOREIGN TAX CREDIT”
- Title VII, Subtitle A, Section 70309: SPACEPORTS ARE TREATED LIKE AIRPORTS UNDER EXEMPT FACILITY BOND RULES (b)Income tax, individuals and businesses
Amends section 142(b)(1) of the Internal Revenue Code of 1986.
“Section 142(b)(1) is amended by adding at the end the following new subparagraph: ``(C) Special rule for spaceport ground leases.--For purposes of subparagraph (A), spaceport property located on land leased by a governmental unit from the United States shall not fail to be treated as owned by a governmental unit if the requirements of this paragraph are met by the lease and any subleases of the property.''.”
Effective date, in the law’s words (subsection (f)): “The amendments made by this section shall apply to obligations issued after the date of the enactment of this Act. Subchapter B--Permanent America-first International Tax Reforms PART I--FOREIGN TAX CREDIT”
- Title VII, Subtitle A, Section 70309: SPACEPORTS ARE TREATED LIKE AIRPORTS UNDER EXEMPT FACILITY BOND RULES (c)Income tax, individuals and businesses
Amends section 142 of the Internal Revenue Code of 1986.
“Section 142 is amended by adding at the end the following new subsection: ``(p) Spaceport.-- ``(1) In general.--For purposes of subsection (a)(1), the term `spaceport' means any facility located at or in close proximity to a launch site or reentry site used for-- ``(A) manufacturing, assembling, or repairing spacecraft, space cargo, other facilities described in this paragraph, or any component of the foregoing, ``(B) flight control operations, ``(C) providing launch services and reentry services, or ``(D) transferring crew, spaceflight participants, or space cargo to or from spacecraft.”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (f)): “The amendments made by this section shall apply to obligations issued after the date of the enactment of this Act. Subchapter B--Permanent America-first International Tax Reforms PART I--FOREIGN TAX CREDIT”
- Title VII, Subtitle A, Section 70309: SPACEPORTS ARE TREATED LIKE AIRPORTS UNDER EXEMPT FACILITY BOND RULES (d)Income tax, individuals and businesses
Amends section 149(b)(3) of the Internal Revenue Code of 1986.
“Section 149(b)(3) is amended by adding at the end the following new subparagraph: ``(F) Exception for spaceports.--A bond shall not be treated as federally guaranteed merely because of the payment of rent, user fees, or other charges by the United States (or any agency or instrumentality thereof) in exchange for the use of the spaceport by the United States (or any agency or instrumentality thereof).''.”
Effective date, in the law’s words (subsection (f)): “The amendments made by this section shall apply to obligations issued after the date of the enactment of this Act. Subchapter B--Permanent America-first International Tax Reforms PART I--FOREIGN TAX CREDIT”
- Title VII, Subtitle A, Section 70311: MODIFICATIONS RELATED TO FOREIGN TAX CREDIT LIMITATION (a)Income tax, individuals and businesses
Amends section 904(b) of the Internal Revenue Code of 1986.
“Section 904(b) is amended by adding at the end the following new paragraph: ``(5) Deductions treated as allocable to foreign source net cfc tested income.--Solely for purposes of the application of subsection (a) with respect to amounts described in subsection (d)(1)(A), the taxpayer's taxable income from sources without the United States shall be determined by allocating and apportioning-- ``(A) any deduction allowed under section 250(a)(1)(B) (and any deduction allowed under section 164(a)(3) for taxes imposed on amounts described in section 250(a)(1)(B)) to such income, ``(B) no amount of interest expense or research and experimental expenditures to such income, and ``(C) any other”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70311: MODIFICATIONS RELATED TO FOREIGN TAX CREDIT LIMITATION (b)Income tax, individuals and businesses
Amends section 904(d)(2)(H)(i) of the Internal Revenue Code of 1986.
“Section 904(d)(2)(H)(i) is amended by striking ``paragraph (1)(B)'' and inserting ``paragraph (1)(D)''. (2)”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70311: MODIFICATIONS RELATED TO FOREIGN TAX CREDIT LIMITATION (b)Income tax, individuals and businesses
Amends section 904(d)(4)(C)(ii) of the Internal Revenue Code of 1986.
“Section 904(d)(4)(C)(ii) is amended by striking ``paragraph (1)(A)'' and inserting ``paragraph (1)(C)''. (3)”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70311: MODIFICATIONS RELATED TO FOREIGN TAX CREDIT LIMITATION (b)Income tax, individuals and businesses
Amends section 951A(f)(1)(A) of the Internal Revenue Code of 1986.
“Section 951A(f)(1)(A) is amended by striking ``904(h)(1)'' and inserting ``904(h)''.”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70312: MODIFICATIONS TO DETERMINATION OF DEEMED PAID CREDIT FOR TAXES PROPERLY ATTRIBUTABLE TO TESTED INCOME (a)Income tax, individuals and businesses
Amends section 960(d)(1) of the Internal Revenue Code of 1986.
Old New 80 percent 90 percent “Section 960(d)(1) is amended by striking ``80 percent'' and inserting ``90 percent''. (2) Gross up for deemed paid foreign tax credit.--”
Effective date, in the law’s words (subsection (c)): “(1) In general.--The amendments made by subsection (a) shall apply to taxable years beginning after December 31, 2025. (2) Disallowance.--The amendment made by subsection (b) shall apply to foreign income taxes paid or accrued (or deemed paid under section 960(b)(1) of the Internal Revenue Code of 1986) with respect to any amount excluded from gross income under section 959(a) of such Code by reason of an inclusion” The quote stops here.
- Title VII, Subtitle A, Section 70312: MODIFICATIONS TO DETERMINATION OF DEEMED PAID CREDIT FOR TAXES PROPERLY ATTRIBUTABLE TO TESTED INCOME (a)Income tax, individuals and businesses
Amends section 78 of the Internal Revenue Code of 1986.
Old New 80 percent 90 percent “Section 78 is amended-- (A) by striking ``subsections (a), (b), and (d)'' and inserting ``subsections (a) and (d)'', and (B) by striking ``80 percent'' and inserting ``90 percent''.”
Effective date, in the law’s words (subsection (c)): “(1) In general.--The amendments made by subsection (a) shall apply to taxable years beginning after December 31, 2025. (2) Disallowance.--The amendment made by subsection (b) shall apply to foreign income taxes paid or accrued (or deemed paid under section 960(b)(1) of the Internal Revenue Code of 1986) with respect to any amount excluded from gross income under section 959(a) of such Code by reason of an inclusion” The quote stops here.
- Title VII, Subtitle A, Section 70312: MODIFICATIONS TO DETERMINATION OF DEEMED PAID CREDIT FOR TAXES PROPERLY ATTRIBUTABLE TO TESTED INCOME (b)Income tax, individuals and businesses
Amends section 960(d) of the Internal Revenue Code of 1986.
“Section 960(d) is amended by adding at the end the following new paragraph: ``(4) Disallowance of foreign tax credit with respect to distributions of previously taxed net cfc tested income.--No credit shall be allowed under section 901 for 10 percent of any foreign income taxes paid or accrued (or deemed paid under subsection (b)(1)) with respect to any amount excluded from gross income under section 959(a) by reason of an inclusion in gross income under section 951A(a).''.”
Effective date, in the law’s words (subsection (c)): “(1) In general.--The amendments made by subsection (a) shall apply to taxable years beginning after December 31, 2025. (2) Disallowance.--The amendment made by subsection (b) shall apply to foreign income taxes paid or accrued (or deemed paid under section 960(b)(1) of the Internal Revenue Code of 1986) with respect to any amount excluded from gross income under section 959(a) of such Code by reason of an inclusion” The quote stops here.
- Title VII, Subtitle A, Section 70313: SOURCING CERTAIN INCOME FROM THE SALE OF INVENTORY PRODUCED IN THE UNITED STATES (a)Income tax, individuals and businesses
Amends section 904(b) of the Internal Revenue Code of 1986.
“Section 904(b), as amended by section 70311, is amended by adding at the end the following new paragraph: ``(6) Source rules for certain inventory produced in the united states and sold through foreign branches.--For purposes of this section, if a United States person maintains an office or other fixed place of business in a foreign country (determined under rules similar to the rules of section 864(c)(5)), the portion of income which-- ``(A) is from the sale or exchange outside the United States of inventory property (within the meaning of section 865(i)(1))-- ``(i) which is produced in the United States, ``(ii) which is for use outside the United States, and ``(iii) to which the third”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (b)): “The amendment made by this section shall apply to taxable years beginning after December 31, 2025. PART II--FOREIGN-DERIVED DEDUCTION ELIGIBLE INCOME AND NET CFC TESTED INCOME”
- Title VII, Subtitle A, Section 70323: RULES RELATED TO DEEMED INTANGIBLE INCOME (a)Income tax, individuals and businesses
Amends section 951A(a) of the Internal Revenue Code of 1986.
“Section 951A(a) is amended by striking ``global intangible low-taxed income'' and inserting ``net CFC tested income''. (2) Repeal of tax-free deemed return on foreign investments.--”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025. PART III--BASE EROSION MINIMUM TAX”
- Title VII, Subtitle A, Section 70323: RULES RELATED TO DEEMED INTANGIBLE INCOME (a)Income tax, individuals and businesses
Amends section 951A of the Internal Revenue Code of 1986.
“Section 951A, as amended by the preceding provisions of this Act, is amended by striking subsections (b) and (d) and by redesignating subsections (c), (e), and (f) as subsections (b), (c), and (d), respectively. (3) Conforming amendments.-- (A)(i) Section 250 is amended by striking ``global intangible low-taxed income'' each place it appears in subsections (a)(1)(B)(i), (a)(2), and (b)(3)(A)(i)(II) and inserting ``net CFC tested income''. (ii)”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025. PART III--BASE EROSION MINIMUM TAX”
- Title VII, Subtitle A, Section 70323: RULES RELATED TO DEEMED INTANGIBLE INCOME (a)Income tax, individuals and businesses
Amends section 951A(c)(1) of the Internal Revenue Code of 1986.
“Section 951A(c)(1), as redesignated by paragraph (2), is amended by striking ``subsections (b), (c)(1)(A), and (c)(1)(B)'' and inserting ``subsections (b)(1)(A) and (b)(1)(B)''. (C)”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025. PART III--BASE EROSION MINIMUM TAX”
- Title VII, Subtitle A, Section 70323: RULES RELATED TO DEEMED INTANGIBLE INCOME (a)Income tax, individuals and businesses
Amends section 951A(d) of the Internal Revenue Code of 1986.
“Section 951A(d), as redesignated by paragraph (2), is amended-- (i) by striking ``global intangible low-taxed income'' each place it appears and inserting ``net CFC tested income'', and (ii) by striking ``subsection (c)(1)(A)'' in paragraph (2)(B)(ii) and inserting ``subsection (b)(1)(A)''. (D)”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025. PART III--BASE EROSION MINIMUM TAX”
- Title VII, Subtitle A, Section 70323: RULES RELATED TO DEEMED INTANGIBLE INCOME (a)Income tax, individuals and businesses
Amends section 960(d)(2) of the Internal Revenue Code of 1986.
“Section 960(d)(2) is amended-- (i) by striking ``global intangible low-taxed income'' in subparagraph (A) and inserting ``net CFC tested income'', and (ii) by striking ``section 951A(c)(1)(A)'' in subparagraph (B) and inserting ``section 951A(b)(1)(A)''. (E)(i) The heading for section 951A is amended by striking ``global intangible low-taxed income'' and inserting ``net cfc tested income''. (ii)”
Effective date, in the law’s words (subsection (c)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025. PART III--BASE EROSION MINIMUM TAX”
- Title VII, Subtitle A, Section 70341: COORDINATION OF BUSINESS INTEREST LIMITATION WITH INTEREST CAPITALIZATION PROVISIONS (a)Income tax, individuals and businesses
Amends section 163(j) of the Internal Revenue Code of 1986.
“Section 163(j) is amended by redesignating paragraphs (10) and (11) as paragraphs (11) and (12) and by inserting after paragraph (9) the following: ``(10) Coordination with interest capitalization provisions.-- ``(A) In general.--In applying this subsection-- ``(i) the limitation under paragraph (1) shall apply to business interest without regard to whether the taxpayer would otherwise deduct such business interest or capitalize such business interest under an interest capitalization provision, and ``(ii) any reference in this subsection to a deduction for business interest shall be treated as including a reference to the capitalization of business interest.”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (d)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70341: COORDINATION OF BUSINESS INTEREST LIMITATION WITH INTEREST CAPITALIZATION PROVISIONS (b)Income tax, individuals and businesses
Amends section 163(j)(5) of the Internal Revenue Code of 1986.
“Section 163(j)(5) is amended by adding at the end the following new sentence: ``Such term shall not include any interest which is capitalized under section 263(g) or 263A(f).''.”
Effective date, in the law’s words (subsection (d)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70341: COORDINATION OF BUSINESS INTEREST LIMITATION WITH INTEREST CAPITALIZATION PROVISIONS (c)Income tax, individuals and businesses
Amends section 163(j) of the Internal Revenue Code of 1986.
“Section 163(j), as amended by subsection (a), is amended by redesignating paragraphs (11) and (12) as paragraphs (12) and (13) and by inserting after paragraph (10) the following: ``(11) Regulatory authority.--The Secretary shall issue such regulations or guidance as may be necessary or appropriate to carry out the purposes of this subsection, including regulations or guidance to determine which business interest is taken into account under this subsection and section 59A(c)(3).''.”
Effective date, in the law’s words (subsection (d)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70342: DEFINITION OF ADJUSTED TAXABLE INCOME FOR BUSINESS INTEREST LIMITATION (a)Income tax, individuals and businesses
Amends section 163(j)(8) of the Internal Revenue Code of 1986.
“Subparagraph (A) of section 163(j)(8) is amended-- (1) by striking ``and'' at the end of clause (iv), and (2) by adding at the end the following new clause: ``(vi) the amounts included in gross income under sections 951(a), 951A(a), and 78 (and the portion of the deductions allowed under sections 245A(a) (by reason of section 964(e)(4)) and 250(a)(1)(B) by reason of such inclusions), and''.”
Effective date, in the law’s words (subsection (b)): “The amendments made by this section shall apply to taxable years beginning after December 31, 2025. PART V--OTHER INTERNATIONAL TAX REFORMS”
- Title VII, Subtitle A, Section 70351: PERMANENT EXTENSION OF LOOK-THRU RULE FOR RELATED CONTROLLED FOREIGN CORPORATIONS (a)Income tax, individuals and businesses
Amends section 954(c)(6)(C) of the Internal Revenue Code of 1986.
“Section 954(c)(6)(C) is amended by striking ``and before January 1, 2026,''.”
Effective date, in the law’s words (subsection (b)): “The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70352: REPEAL OF ELECTION FOR 1-MONTH DEFERRAL IN DETERMINATION OF TAXABLE YEAR OF SPECIFIED FOREIGN CORPORATIONS (a)Income tax, individuals and businesses
Amends section 898(c) of the Internal Revenue Code of 1986.
“Section 898(c) is amended by striking paragraph (2) and redesignating paragraph (3) as paragraph (2).”
Effective date, in the law’s words (subsection (b)): “The amendments made by this section shall apply to taxable years of specified foreign corporations beginning after November 30, 2025.”
- Title VII, Subtitle A, Section 70353: RESTORATION OF LIMITATION ON DOWNWARD ATTRIBUTION OF STOCK OWNERSHIP IN APPLYING CONSTRUCTIVE OWNERSHIP RULES (a)Income tax, individuals and businesses
Amends section 958(b) of the Internal Revenue Code of 1986.
“Section 958(b) is amended-- (1) by inserting after paragraph (3) the following: ``(4) Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person.'', and (2) by striking ``Paragraph (1)'' in the last sentence and inserting ``Paragraphs (1) and (4)''.”
Effective date, in the law’s words (subsection (d)): “The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70353: RESTORATION OF LIMITATION ON DOWNWARD ATTRIBUTION OF STOCK OWNERSHIP IN APPLYING CONSTRUCTIVE OWNERSHIP RULES (b)Income tax, individuals and businesses
Adds section 951B to the Internal Revenue Code of 1986: AMOUNTS INCLUDED IN GROSS INCOME OF FOREIGN CONTROLLED UNITED STATES SHAREHOLDERS.
“Subpart F of part III of subchapter N of chapter 1 is amended by inserting after section 951A the following new section: ``SEC. 951B. AMOUNTS INCLUDED IN GROSS INCOME OF FOREIGN CONTROLLED UNITED STATES SHAREHOLDERS. ``(a) In General.--In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation-- ``(1) this subpart (other than sections 951A, 951(b), and 957) shall be applied with respect to such shareholder (separately from, and in addition to, the application of this subpart without regard to this section)-- ``(A) by substituting `foreign controlled United States shareholder' for `United States shareholder' each place it appears therein, and”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (d)): “The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025.”
- Title VII, Subtitle A, Section 70354: MODIFICATIONS TO PRO RATA SHARE RULES (a)Income tax, individuals and businesses
Amends section 951 of the Internal Revenue Code of 1986.
“Subsection (a) of section 951 is amended to read as follows: ``(a) Amounts Included.-- ``(1) In general.--If a foreign corporation is a controlled foreign corporation at any time during a taxable year of the foreign corporation (in this subsection referred to as the `CFC year')-- ``(A) each United States shareholder which owns (within the meaning of section 958(a)) stock in such corporation on any day during the CFC year shall include in gross income such shareholder's pro rata share (determined under paragraph (2)) of the corporation's subpart F income for the CFC year, and ``(B) each United States shareholder which owns (within the meaning of section 958(a)) stock in such corporation on”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (c)): “(1) In general.--The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025. (2) Transition rule for dividends.--Except to the extent provided by the Secretary of the Treasury (or the Secretary's delegate), a dividend paid (or deemed paid) by a controlled foreign corporation shall not be treated as a dividend for purposes of applying section” The quote stops here.
- Title VII, Subtitle A, Section 70354: MODIFICATIONS TO PRO RATA SHARE RULES (b)Income tax, individuals and businesses
Amends section 951A(b) of the Internal Revenue Code of 1986.
“Section 951A(b), as redesignated by section 70323(a)(2), is amended-- (A) in paragraph (1)(A), by striking ``(determined for each taxable year of such controlled foreign corporation which ends in or with such taxable year of such United States shareholder)'', and (B) in paragraph (1)(B), by striking ``(determined for each taxable year of such controlled foreign corporation which ends in or with such taxable year of such United States shareholder)''. (2) Pro rata share.--”
Effective date, in the law’s words (subsection (c)): “(1) In general.--The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025. (2) Transition rule for dividends.--Except to the extent provided by the Secretary of the Treasury (or the Secretary's delegate), a dividend paid (or deemed paid) by a controlled foreign corporation shall not be treated as a dividend for purposes of applying section” The quote stops here.
- Title VII, Subtitle A, Section 70354: MODIFICATIONS TO PRO RATA SHARE RULES (b)Income tax, individuals and businesses
Amends section 951A(c) of the Internal Revenue Code of 1986.
“Section 951A(c), as redesignated by section 70323(a)(2), is amended-- (A) in paragraph (1), by striking ``in which or with which the taxable year of the controlled foreign corporation ends'' and inserting ``determined under section 951(a)(3)'', and (B) in paragraph (2), by striking ``the last day in the taxable year of such foreign corporation on which such foreign corporation is a controlled foreign corporation'' and inserting ``any day in such taxable year''.”
Effective date, in the law’s words (subsection (c)): “(1) In general.--The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2025. (2) Transition rule for dividends.--Except to the extent provided by the Secretary of the Treasury (or the Secretary's delegate), a dividend paid (or deemed paid) by a controlled foreign corporation shall not be treated as a dividend for purposes of applying section” The quote stops here.
- Title VII, Subtitle A, Section 70401: ENHANCEMENT OF EMPLOYER-PROVIDED CHILD CARE CREDIT (a)Income tax, individuals and businesses
Amends section 45F(a)(1) of the Internal Revenue Code of 1986.
Old New 25 percent 40 percent (50 percent in the case of an eligible small business) “Section 45F(a)(1) is amended by striking ``25 percent'' and inserting ``40 percent (50 percent in the case of an eligible small business)''.”
Effective date, in the law’s words (subsection (g)): “The amendments made by this section shall apply to amounts paid or incurred after December 31, 2025.”
- Title VII, Subtitle A, Section 70401: ENHANCEMENT OF EMPLOYER-PROVIDED CHILD CARE CREDIT (b)Income tax, individuals and businesses
Amends section 45F of the Internal Revenue Code of 1986.
“Subsection (b) of section 45F is amended to read as follows: ``(b) Dollar Limitation.-- ``(1) In general.--The credit allowable under subsection (a) for any taxable year shall not exceed $500,000 ($600,000 in the case of an eligible small business). ``(2) Inflation adjustment.--In the case of any taxable year beginning after 2026, the $500,000 and $600,000 amounts in paragraph (1) shall each be increased by an amount equal to-- ``(A) such dollar amount, multiplied by ``(B) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting `calendar year 2025' for `calendar year 2016' in subparagraph (A)(ii)”
The quote stops here. The law’s text has the rest.
Effective date, in the law’s words (subsection (g)): “The amendments made by this section shall apply to amounts paid or incurred after December 31, 2025.”
- Title VII, Subtitle A, Section 70401: ENHANCEMENT OF EMPLOYER-PROVIDED CHILD CARE CREDIT (c)Income tax, individuals and businesses
Amends section 45F(c) of the Internal Revenue Code of 1986.
“Section 45F(c) is amended by adding at the end the following new paragraph: ``(4) Eligible small business.--The term `eligible small business' means a business that meets the gross receipts test of section 448(c), determined-- ``(A) by substituting `5-taxable-year' for `3- taxable-year' in paragraph (1) thereof, and ``(B) by substituting `5-year' for `3-year' in paragraph (3)(A) thereof.''.”
Effective date, in the law’s words (subsection (g)): “The amendments made by this section shall apply to amounts paid or incurred after December 31, 2025.”
Official estimate, and an estimate of your own
Official estimate: Joint Committee on Taxation
Confirmed from the official recordThe Joint Committee on Taxation is the tax staff of Congress. It published this table for the tax provisions of this law. Amounts are in billions of dollars for one calendar year. “Proposal” is the committee’s word for those provisions.
| Income category | Change in federal taxes, billions | Change, percent | Average tax rate, present law | Average tax rate, proposal |
|---|---|---|---|---|
| Less than $15,000 | $0.5 | 9.3% | 4.0% | 4.4% |
| $15,000 to $30,000 | -$3.5 | -21.5% | 2.9% | 2.3% |
| $30,000 to $40,000 | -$6.4 | -15.8% | 6.6% | 5.6% |
| $40,000 to $50,000 | -$9.0 | -14.5% | 9.0% | 7.7% |
| $50,000 to $60,000 | -$11.8 | -13.2% | 11.3% | 9.8% |
| $60,000 to $80,000 | -$27.0 | -12.0% | 13.1% | 11.5% |
| $80,000 to $100,000 | -$28.8 | -11.5% | 15.4% | 13.7% |
| $100,000 to $150,000 | -$65.5 | -10.7% | 17.3% | 15.5% |
| $150,000 to $200,000 | -$58.2 | -10.7% | 19.8% | 17.6% |
| $200,000 to $500,000 | -$150.8 | -9.8% | 24.1% | 21.8% |
| $500,000 to $1,000,000 | -$72.8 | -12.3% | 29.8% | 26.1% |
| $1,000,000 and Above | -$114.0 | -10.1% | 31.1% | 27.8% |
| Total, All Taxpayers | -$547.4 | -10.7% | 20.9% | 18.7% |
A negative number is a tax cut for that income category as a whole. The table gives no amount for one household. The committee’s footnotes say what counts as income and as federal taxes. They are in the file.
Joint Committee on Taxation, JCX-37-25, July 29, 2025: Distribution of the estimated revenue effects relative to the present law baseline of the tax provisions in Public Law 119-21. See its official page · Open our saved copy · Saved October 8, 2026 · Fingerprint d4b6df30545ba2b0
Show 2029, 2031 and 2033
| Income category | Change in federal taxes, billions | Change, percent | Average tax rate, present law | Average tax rate, proposal |
|---|---|---|---|---|
| Less than $15,000 | $2.0 | 42.2% | 3.3% | 4.7% |
| $15,000 to $30,000 | $0.3 | 1.6% | 3.1% | 3.2% |
| $30,000 to $40,000 | -$3.6 | -8.2% | 6.6% | 6.1% |
| $40,000 to $50,000 | -$6.0 | -8.8% | 9.1% | 8.3% |
| $50,000 to $60,000 | -$9.0 | -9.2% | 11.3% | 10.3% |
| $60,000 to $80,000 | -$22.3 | -9.0% | 13.1% | 11.9% |
| $80,000 to $100,000 | -$23.5 | -8.5% | 15.4% | 14.1% |
| $100,000 to $150,000 | -$52.1 | -7.9% | 17.2% | 15.9% |
| $150,000 to $200,000 | -$46.7 | -8.0% | 19.8% | 18.2% |
| $200,000 to $500,000 | -$135.0 | -8.1% | 24.3% | 22.3% |
| $500,000 to $1,000,000 | -$64.3 | -10.2% | 29.9% | 26.8% |
| $1,000,000 and Above | -$87.6 | -7.6% | 30.8% | 28.3% |
| Total, All Taxpayers | -$447.8 | -8.2% | 20.8% | 19.1% |
| Income category | Change in federal taxes, billions | Change, percent | Average tax rate, present law | Average tax rate, proposal |
|---|---|---|---|---|
| Less than $15,000 | $2.4 | 49.4% | 3.1% | 4.7% |
| $15,000 to $30,000 | $1.0 | 4.7% | 3.4% | 3.5% |
| $30,000 to $40,000 | -$3.6 | -7.6% | 6.7% | 6.2% |
| $40,000 to $50,000 | -$6.2 | -8.4% | 9.1% | 8.3% |
| $50,000 to $60,000 | -$9.5 | -9.0% | 11.3% | 10.3% |
| $60,000 to $80,000 | -$22.8 | -8.6% | 13.1% | 12.0% |
| $80,000 to $100,000 | -$24.5 | -8.1% | 15.5% | 14.2% |
| $100,000 to $150,000 | -$51.4 | -7.2% | 17.1% | 15.8% |
| $150,000 to $200,000 | -$43.3 | -6.9% | 19.7% | 18.3% |
| $200,000 to $500,000 | -$105.7 | -5.8% | 24.3% | 22.9% |
| $500,000 to $1,000,000 | -$57.1 | -8.5% | 29.9% | 27.3% |
| $1,000,000 and Above | -$77.5 | -6.5% | 30.7% | 28.6% |
| Total, All Taxpayers | -$398.1 | -6.8% | 20.7% | 19.3% |
| Income category | Change in federal taxes, billions | Change, percent | Average tax rate, present law | Average tax rate, proposal |
|---|---|---|---|---|
| Less than $15,000 | $2.8 | 56.1% | 3.0% | 4.7% |
| $15,000 to $30,000 | $1.1 | 4.6% | 3.6% | 3.8% |
| $30,000 to $40,000 | -$4.2 | -8.1% | 6.8% | 6.3% |
| $40,000 to $50,000 | -$6.3 | -8.1% | 8.9% | 8.2% |
| $50,000 to $60,000 | -$10.0 | -8.9% | 11.1% | 10.1% |
| $60,000 to $80,000 | -$25.3 | -8.8% | 13.1% | 12.0% |
| $80,000 to $100,000 | -$26.9 | -8.1% | 15.5% | 14.2% |
| $100,000 to $150,000 | -$55.5 | -7.1% | 17.0% | 15.7% |
| $150,000 to $200,000 | -$46.5 | -6.8% | 19.6% | 18.2% |
| $200,000 to $500,000 | -$113.6 | -5.7% | 24.4% | 23.0% |
| $500,000 to $1,000,000 | -$57.3 | -7.9% | 30.0% | 27.6% |
| $1,000,000 and Above | -$76.7 | -6.0% | 30.6% | 28.7% |
| Total, All Taxpayers | -$418.2 | -6.6% | 20.7% | 19.3% |
Show the same estimate measured against the current policy baseline (JCX-36-25)
| Income category | Change in federal taxes, billions | Change, percent | Average tax rate, present law | Average tax rate, proposal |
|---|---|---|---|---|
| Less than $15,000 | $2.8 | 70.8% | 2.8% | 4.7% |
| $15,000 to $30,000 | $6.0 | 46.0% | 2.2% | 3.2% |
| $30,000 to $40,000 | $2.3 | 6.1% | 5.7% | 6.1% |
| $40,000 to $50,000 | $0.8 | 1.2% | 8.2% | 8.3% |
| $50,000 to $60,000 | -$0.9 | -1.0% | 10.4% | 10.3% |
| $60,000 to $80,000 | -$3.0 | -1.3% | 12.1% | 11.9% |
| $80,000 to $100,000 | -$3.7 | -1.4% | 14.3% | 14.1% |
| $100,000 to $150,000 | -$8.2 | -1.3% | 16.1% | 15.9% |
| $150,000 to $200,000 | -$9.2 | -1.7% | 18.5% | 18.2% |
| $200,000 to $500,000 | -$34.7 | -2.2% | 22.8% | 22.3% |
| $500,000 to $1,000,000 | -$9.0 | -1.6% | 27.2% | 26.8% |
| $1,000,000 and Above | -$23.1 | -2.1% | 29.0% | 28.3% |
| Total, All Taxpayers | -$79.9 | -1.6% | 19.4% | 19.1% |
| Income category | Change in federal taxes, billions | Change, percent | Average tax rate, present law | Average tax rate, proposal |
|---|---|---|---|---|
| Less than $15,000 | $3.3 | 84.3% | 2.5% | 4.7% |
| $15,000 to $30,000 | $7.0 | 45.0% | 2.4% | 3.5% |
| $30,000 to $40,000 | $2.5 | 6.2% | 5.8% | 6.2% |
| $40,000 to $50,000 | $0.9 | 1.3% | 8.2% | 8.3% |
| $50,000 to $60,000 | -$0.8 | -0.8% | 10.3% | 10.3% |
| $60,000 to $80,000 | -$2.1 | -0.9% | 12.1% | 12.0% |
| $80,000 to $100,000 | -$2.7 | -1.0% | 14.3% | 14.2% |
| $100,000 to $150,000 | -$4.3 | -0.6% | 15.9% | 15.8% |
| $150,000 to $200,000 | -$3.6 | -0.6% | 18.4% | 18.3% |
| $200,000 to $500,000 | $1.6 | 0.1% | 22.9% | 22.9% |
| $500,000 to $1,000,000 | -$0.9 | -0.1% | 27.3% | 27.3% |
| $1,000,000 and Above | -$10.8 | -1.0% | 28.8% | 28.6% |
| Total, All Taxpayers | -$9.9 | -0.2% | 19.3% | 19.3% |
| Income category | Change in federal taxes, billions | Change, percent | Average tax rate, present law | Average tax rate, proposal |
|---|---|---|---|---|
| Less than $15,000 | $3.8 | 98.7% | 2.4% | 4.7% |
| $15,000 to $30,000 | $7.6 | 43.0% | 2.6% | 3.8% |
| $30,000 to $40,000 | $2.3 | 5.1% | 6.0% | 6.3% |
| $40,000 to $50,000 | $1.0 | 1.5% | 8.1% | 8.2% |
| $50,000 to $60,000 | -$0.9 | -0.8% | 10.2% | 10.1% |
| $60,000 to $80,000 | -$3.0 | -1.1% | 12.1% | 12.0% |
| $80,000 to $100,000 | -$3.2 | -1.0% | 14.3% | 14.2% |
| $100,000 to $150,000 | -$5.1 | -0.7% | 15.9% | 15.7% |
| $150,000 to $200,000 | -$4.4 | -0.7% | 18.4% | 18.2% |
| $200,000 to $500,000 | $2.3 | 0.1% | 23.0% | 23.0% |
| $500,000 to $1,000,000 | $0.7 | 0.1% | 27.5% | 27.6% |
| $1,000,000 and Above | -$7.6 | -0.6% | 28.8% | 28.7% |
| Total, All Taxpayers | -$6.3 | -0.1% | 19.4% | 19.3% |
Joint Committee on Taxation, JCX-36-25, July 29, 2025: Distribution of the estimated revenue effects relative to the current policy baseline of the tax provisions in Public Law 119-21. See its official page · Open our saved copy · Saved October 8, 2026 · Fingerprint 81b95a0a0d4c2968
Joint Committee on Taxation, JCX-35-25, July 1, 2025: Estimated revenue effects, relative to the present law baseline, of the tax provisions in Title VII of the bill as the Senate passed it (JCX-35-25). See its official page · Open our saved copy · Saved October 8, 2026 · Fingerprint b33299c3d829aa38
The table in this file is printed in a way a rule cannot read with certainty. Our copy is saved and linked. No number from it is shown.
Estimate: 2025 income tax with and without this law
EstimateThe change Public Law 119-21 makes to the standard deduction for tax year 2025. The 2025 tax rate tables are the same with and without the law.
Nothing typed here is stored or logged. With scripts on, this browser works out the estimate and sends nothing.
| Filing status | Under the law | Without it |
|---|---|---|
| Married filing jointly, or surviving spouse | $31,500 | $30,000 |
| Head of household | $23,625 | $22,500 |
| Single | $15,750 | $15,000 |
| Married filing separately | $15,750 | $15,000 |
Internal Revenue Service, Rev. Proc. 2024-40, November 4, 2024: Revenue Procedure 2024-40, Internal Revenue Bulletin 2024-45: tax rate tables and standard deduction for tax year 2025, as the law stood on October 22, 2024. See its official page · Open our saved copy · Saved October 8, 2026 · Fingerprint 3f72cb99cc257c41
Internal Revenue Service, Rev. Proc. 2025-32, November 3, 2025: Revenue Procedure 2025-32, Internal Revenue Bulletin 2025-45: changes to the 2025 items of Revenue Procedure 2024-40 made by Public Law 119-21. See its official page · Open our saved copy · Saved October 8, 2026 · Fingerprint cc4022d0c545db20
How the estimate is worked out, and what it leaves out
- Taxable income = income before the standard deduction, minus the standard deduction (never below zero).
- Income tax = the amount the 2025 tax rate table gives for that taxable income.
- Difference = income tax under the law minus income tax without it.
The estimate leaves out:
- the added deduction for people 65 and older or blind, and the law's new deduction for seniors
- the law's new deductions for tips, overtime pay and car loan interest
- the child tax credit and every other credit
- itemized deductions, including the limit on the deduction for State and local taxes
- capital gains and qualified dividends, which have their own rates
- the alternative minimum tax, payroll taxes and State taxes
- every change that starts in tax year 2026 or later
For taxable income under $100,000 the tax table of the Internal Revenue Service works in $50 steps, so the tax on a return can differ from this estimate by a few dollars.
Where this comes from
The provisions are read from our own saved copy of the law. The code beside it is its fingerprint, a short code that changes if the file’s contents change.
Read from: Public Law 119-21, official text · Saved October 5, 2026 · Fingerprint 84000b07c382db50
How we read a law for this section
- A provision is one sentence of the law that says a part of a tax law "is amended" or "is repealed". The words are quoted from our saved copy of the law. Words inside text the law inserts into another law are not read as provisions.
- A sentence counts when it names the Internal Revenue Code of 1986 or title 26 of the United States Code; when it says "such Code" and the last Code named in that section of the law is the Internal Revenue Code of 1986; when the law says that its amendments are to be read as amendments to the Internal Revenue Code of 1986 and the sentence names no other law; or when the sentence names no law at all and the amending sentence before it, in the same section of the law, amended the Internal Revenue Code of 1986.
- A sentence that amends the Harmonized Tariff Schedule of the United States or the Tariff Act of 1930 is listed under "Tariffs and customs duties".
- The tax type comes from the number of the Code section the sentence names. Sections 1 to 5, 21 to 26, 32, 35, 36, 36B, 62, 63, 67, 68, 151 to 153 and 211 to 224 apply to individuals: "Individual income tax". Sections 11, 12, 59A, 241 to 250, 301 to 385, 531 to 565 and 1501 to 1564 apply to corporations: "Corporate income tax". Every other section from 1 to 1400Z and 1411 to 1564 is "Income tax, individuals and businesses". Sections 1401 to 1403 and 3101 to 3512: "Payroll taxes". Sections 2001 to 2801: "Estate and gift taxes". Sections 4001 to 5891: "Excise taxes". Every other section, such as the rules on returns, penalties and trust funds: "Other tax law".
- A sentence that names a chapter or subtitle of the Code and no section is sorted by that chapter or subtitle. A sentence that adds a new section is sorted by the new section's number.
- "Old and new" is shown only where the law says both: "striking X and inserting Y". Other dollar amounts and percentages in the sentence are listed as printed.
- A change to a table of contents or a change headed "Conforming" or "Clerical" is listed apart.
- A law reads "This law changes no tax" only when our saved copy reaches the end of the law, no sentence above is found, the text does not name the Internal Revenue Code of 1986, the Internal Revenue Service, the Harmonized Tariff Schedule of the United States, a tariff, a duty or a named tax, and the margin of the official print cites title 26 of the United States Code nowhere.
- Nothing here says how much tax anyone pays. That takes figures the law's text does not state.