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TAX TAKE: A Second Chance at a Tax Bill

Tax Alert

It's not certain, but another tax bill – either a second partisan reconciliation bill or a bipartisan year-end bill – could gain traction in the closing months of 2025. Assuming the drive for another bite at the tax apple does materialize, this week's Tax Take examines those tax relief provisions that are likely to be considered. 

Here's a broad sketch of the potential tax relief in play this autumn: 

  • Tax "extenders" expiring at the end of 2025, including the enhanced Affordable Care Act (ACA) premium tax credit, the work opportunity tax credit, the Section 181 expensing rules, and the seven-year recovery period for motorsports entertainment complexes.
  • House-passed tax relief dropped from the One Big Beautiful Bill Act (OBBBA), including an increase in the section 199A pass-through deduction and expansion of the use of health savings accounts.
  • Revisiting tax provisions enacted in OBBBA, including the 90 percent limitation on the deduction of wagering losses, the individual and corporate charitable contribution deduction "floors," and perhaps the interaction of research and development (R&D) expensing with the Corporate Alternative Minimum Tax (CAMT) and Base Erosion and Anti-Abuse Tax (BEAT).
  • Remaining international tax relief provisions in Senator Thom Tillis' (R-NC) bill (S. 1605), including the BEAT high-tax exception.
  • Tax relief proposals advanced by President Trump, including potential capital gains relief for home sales and perhaps an extension of the temporary OBBBA tax relief provisions such as "no tax on tips."
  • Tax relief provisions that would require a bipartisan non-reconciliation vehicle, including the Taiwan "treaty" legislation, retirement savings incentives (Secure 3.0), and technical corrections.
  • A variety of other provisions, including expansion of the child tax credit, extension of the Section 48D advanced manufacturing semiconductor tax credit, digital asset taxation rules, and tax rules for Americans living abroad.

The timing and scope of an autumn tax bill is uncertain, but supporters of these tax relief provisions – and many others – are already advocating to be included on this "second-chance" tax menu.

Next week, we will turn to the less-popular topic of revenue raisers that may be considered in funding any second tax bill that emerges. #TaxTake



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