The tax provisions of the One Big, Beautiful Bill Act (OBBBA; H.R. 1), which passed the House of Representatives on May 22, 2025, are largely the same as the version of the bill that was released on Monday, May 12, 2025. See Spidell’s Flash E-mail from May 12 for a summary of the bill’s major provisions.
Two significant changes that were made in the last-minute tax amendments to the OBBBA version that was passed by the House include:
- An increase in the SALT itemized deduction limitation to $40,000 ($20,000 for married taxpayers filing separately) and an increase in the modified adjusted gross income phaseout threshold to $500,000 ($250,000 MFS); and
- Modifications to the excess business loss rules under IRC §461(l) that create a separate category of carryovers for excess business losses instead of treating them as net operating losses.
The bill passed by the House did not delete the modifications to the SALT limitation that effectively remove the benefits of state passthrough entity elective tax laws.
The final version of the bill, without the last-minute amendments, is available at:
www.congress.gov/bill/119th-congress/house-bill/1/text
And the supplemental amendments that were a part of the final bill are available at:
http://rules.house.gov/sites/evo-subsites/rules.house.gov/files/documents/rulesreport05212025_.pdf
This is just the next step in the evolution of this legislation, and we will continue to keep you posted as news develops on these pending provisions.
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