President Trump Enacts the One, Big, Beautiful Bill Act

President Trump Enacts the One, Big, Beautiful Bill Act

President Trump Enacts the One, Big, Beautiful Bill Act 400 400 SAX

On July 4, 2025, President Trump signed the One, Big, Beautiful Bill Act (OBBB) into law, enacting significant tax reforms with wide-ranging implications for individuals and businesses.

Aimed at delivering meaningful tax relief to the middle class and small businesses, the OBBB brings several notable changes:

Individual Provisions:

  • SALT deduction cap increased from $10,000 to $40,000, with a phaseout beginning at $500,000.
  • No limitation on the use of Pass-Through Entity Taxes (PTET) as a SALT deduction workaround.
  • Permanent increase of the Child Tax Credit to $2,200 per child, with $1,700 as a refundable.
  • Estate tax exemption raised permanently to $15 million starting in 2026 and adjusted for inflation.
  • No tax on tips and overtime – Above-the-line deduction subject to income-based phaseouts.
  • No Tax on Car Loan Interest – Deduction of up to $10,000 in interest on new car loans (2025-2028) for vehicles assembled in the U.S., subject to income limitations.
  • Charitable deduction for non-itemizers.  A $1,000 above-the-line deduction for single and $2,000 for married.

Business Provisions:

  • Permanent increase to the Qualified Business Income Deduction (199A) at 20% of qualifying business income. Owners of specified service trade or business (SSTB) may benefit from an increased phase-out limitation. Includes a minimum deduction of $400 for certain taxpayers.
  • Allows full deduction of domestic R&D expenditures in the year incurred, for tax years beginning after 12/31/24. Also includes provisions to accelerate the deduction of previously capitalized R&D expenses.
  • Reinstates the EBITDA limitation under Sec. 163(j) for tax years beginning after December 31, 2024.
  • 100% bonus depreciation made permanent for qualified property acquired and placed in service after January 19, 2025.
  • 100% depreciation allowance on certain US facilities that produce tangible personal property subject to certain requirements and placed in service before 1/1/2031.
  • Increase section 179 deduction to $2,500,000 from $1,250,000 with increased the phaseout threshold amount to $4 million.
  • Retroactively terminate the Employee Retention Tax Credit (ERC) for taxpayers who filed refund claims after January 31, 2024. Increases enforcement mechanisms.
  • Opportunity Zones made permanent on a rolling 10-year basis, starting on January 1, 2027.
  • Expansion of the Sec. 1202 exclusion on Qualified Small Business Stock.
  • Tip credit for employer-paid FICA expanded to beauty service industry.
  • Termination of clean energy tax incentives.
  • Increases threshold from $600 to $2,000 for certain Form 1099 Reporting and reinstates the pre-ARPA threshold for 1099-K reporting ($20,000 and 200 transactions).

International Provisions:

  • Permanent overhaul of GILTI and FDII regimes.
    • GILTI is rebranded as Net CFC Tested Income (NCTI); effective for tax years beginning after December 31, 2025, with the prior 37.5% deduction eliminated. The effective GILTI (NCTI) tax rate is now 14% (up from 13.125%). 
    • FDII is retitled Foreign-Derived Deduction Eligible Income (FDDEI) and also taxed at 14%, aligning with the revised GILTI rate.
  • Reinstatement of CFC ownership attribution rule (Sec 958(b)(4)).
    • This restores the prior rule to prevent automatic downward attribution of foreign corporate ownership—avoiding unintentional creation of additional CFCs and more Subpart F filings.
  • BEAT rate set permanently at 10.5%.
    • The Base Erosion Anti-Abuse Tax rate is fixed at 10.5% for taxable years after December 31, 2025.
  • New 1% excise tax on certain cross-border remittances.
    • Beginning January 1, 2026 for transfers sent after December 31, 2025, a 1% tax applies to cash-based remittances (e.g., cash, money orders, cashier’s checks). Exemptions include transfers via U.S. based bank accounts or U.S.-issued debit/credit cards.

If you have any questions or would like to discuss the above, please contact your SAX Advisor.

SAX