It's a long shot, but if a second tax bill – partisan or bipartisan – materializes, will it include revenue raisers? Last week, we focused on tax relief that could be considered in a second tax bill. This week, we examine the flip side: on the assumption that any proposed tax relief would need to be offset, at least in part, by revenue increases. 

Here are revenue raisers considered, or rumored to be considered, for inclusion in the One Big Beautiful Bill Act (OBBBA) that could re-emerge to fund a second tax bill. To be clear, Tax Take does not support or suggest the use of these or other revenue offsets – this list is for informational purposes only. 

• The proposed section 899 international retaliation proposal (depending on the status of the global minimum tax negotiations and implementation)
• An increase in the private foundation net investment income excise tax as passed by the House
• A limitation on sports franchise amortization as passed by the House
• A limitation on the ability of corporations and other business entities to deduct state and local taxes (SALT)
• An excise tax on third party litigation financing (S. 1821/H.R. 3512)
• An increase in the section 4501 stock buyback excise tax
• An expansion of the section 162(m) limitation on excessive employee compensation
• As proposed by President Trump, changes to the taxation of carried interest or a so-called "millionaire" tax (such as reinstatement of the 39.6 percent top individual tax rate) on the wealthy

The need for revenue offsets is often the death knell for tax relief, so our list here is also a list of reasons why an autumn tax bill may not gain traction. Nonetheless, because these provisions were in the mix during consideration of the OBBBA, it's only prudent to be prepared that they may be on the table again. #TaxTake

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