Last week, the House of Representatives approved H.R. 1, the One Big Beautiful Bill Act, that carries the president's major policy initiatives on taxes, spending restraints, border enforcement, military funding, and energy development. Prior to passage, the House Rules Committee adopted a manager's amendment that made a number of significant tax changes to the bill, including:

• An increase in the individual state and local tax (SALT) deduction cap to $40,000, with a phase-out threshold beginning at $500,000 and the cap and threshold increasing by one percent for the next 10 years
• Accelerating the phase-out date of several Inflation Reduction Act (IRA) green energy credits
• Modest changes to the global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), and base erosion and anti-abuse tax (BEAT) rates in an effort to make the provisions compliant with the Byrd Rule
• Reducing the new proposed 5 percent excise tax on foreign remittances to 3.5 percent

The bill now heads to the Senate where, as we previewed last week, significant changes are anticipated. The scope and process for considering these changes will determine the ultimate timing of the bill. Right now, it's not certain if Senate Republican leaders will route the bill through various committees or patch together changes behind closed doors.

While July 4 remains the target date of enactment, it could easily slip. The bill may pass the Senate by that date, but the House and
Senate negotiation of a final package could drag into August. Of course, the need to address the debt limit "X date" at some point in August and the expiration of the underlying budget reconciliation instructions on September 30 are certain to hasten final passage. #TaxTake

Upcoming Speaking Engagements

Jorge and Marc will moderate the "Tax Legislative Outlook" panel at the Federal Bar Association's Insurance Tax Seminar on May 29.

Marc will present a legal and regulatory outlook at the CalCPA 2025 Entertainment Industry Conference on June 26.  

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