Individual Key Tax Provisions
| Tax Provision | Current Law | House Bill | Senate Bill (Approved by House) |
| Individual Income Tax Rates | TCJA rates expire after 2025; seven brackets return to pre-TCJA. | Makes TCJA rates permanent; inflation-adjusted. | Same as House; adds extra year of inflation for 10% and 12% brackets. |
| Standard Deduction | Reverts to pre-TCJA after 2025. | Single $16k, HoH $24k, MFJ $32k. | Single $15.75k, HoH $23.625k, MFJ $31.5k (all indexed). |
| Personal Exemptions | Suspended through 2025; returns 2026. | Permanently repealed. | Same as House. |
| Child Tax Credit | $2,000 per child; reverts to $1,000 after 2025. | $2,500 per child (2025–2028), $2,000 afterward; stricter SSN rules. | $2,200 per child; $1,700 refundable; only one SSN needed if married. |
| Earned Income Tax Credit | No certification required; Form 8867 for preparers. | New IRS certification required from 2028. | Not addressed. |
| Other Dependent Credit | $500 non-refundable credit; expires after 2025. | Made permanent. | Same as House. |
| Estate and Gift Tax Exemption | $13.61M (2024), reverts to ~$5M after 2025. | $15M (indexed from 2026); made permanent. | Same as House. |
| AMT Exemption | Higher TCJA levels expire after 2025. | Makes permanent. | Increases phase-out rate to 50%; steeper claw-back. |
| Mortgage Interest Deduction | $750k debt limit expires after 2025. | Limit made permanent. | Same as House; includes mortgage insurance premiums. |
| Home Equity Debt | Disallowed unless for acquisition; expires after 2025. | Disallowance made permanent. | Same as House. |
| Casualty Loss Deduction | Allowed only for federally declared disasters through 2025. | Makes limitation permanent; defines disasters as of H.R. 1 enactment. | Same as House, adds some state-declared disasters. |
| Misc. Itemized Deductions | Suspended through 2025. | Permanently eliminated. | Same as House; removes educator unreimbursed expenses. |
| Pease Limitation | Suspended through 2025. | Permanently repeals; new $0.35/$0.32 per $1 limit for high earners. | Same, excludes Sec. 199A deduction from cap. |
| Moving Expenses | Suspended (except Armed Forces). | Permanently disallowed. | Same as House. |
| Wagering Losses | Limited to winnings. | Limits to 90% of losses, only up to winnings. | Same as House. |
| Charity Deduction (Non-Itemizers) | Not available after 2021. | $150 ($300 joint) for 2025–2028. | $1,000 single / $2,000 MFJ; permanent. |
| Charity Deduction (Itemizers) | Deductible if over AGI limits. | Not addressed. | Limited to contributions exceeding 0.5% of contribution base. |
| Excise Tax on Remittances | None. | 3.5% tax from 2026; collected by RTPs. | 1% tax from 2026; same enforcement. |
| Tips Deduction | Tips are taxable. | Deductible (except high-income); ends 2028; $160k income limit. | Capped at $25k; phase-out starts at $150k/$300k; ends 2028. |
| Overtime Deduction | Taxable income. | Deductible; ends 2028. | Capped at $12,500 with income limit. |
| Senior Deduction | Extra standard deduction for 65+. | $4,000 bonus (2025–2028). | $6,000 bonus (2025–2028). |
| Car Loan Interest | Not deductible. | Up to $10k deductible on US-assembled car loans (2025–2028). | Same as House. |
| Student Loan Discharge | Exclusion for death/disability ends after 2025. | Makes exclusion permanent; requires SSN. | Same as House. |
| Employer Student Loan Benefit | $5,250 max; expires after 2025. | Made permanent; indexed. | Same as House. |
| Adoption Credit | Nonrefundable. | Adds $5,000 refundable portion; indexed. | Same as House. |
| 529 Plan Uses | Limited to higher ed and $10k K-12. | Expands to homeschool and CPA exam costs. | Same as House. |
| Trump Accounts | N/A | New tax-exempt account with $1,000/child contribution. | Same as House; refinements under discussion. |
| SALT Cap | $10,000 cap. | Raises to $40k ($20k MFS); phased down. | $40k in 2025; indexed until 2029; reverts to $10k in 2030. No cap for pass-throughs. |
| Penalties for Unauthorized Disclosure | $5,000 fine; 5 years prison. | $250,000 fine; 10 years prison. | Not addressed. |
| Contingent Fees (Tax Services) | Generally prohibited. | Allowed for all filings and claims. | Not addressed. |
Business Tax Key Provisions — Detailed Comparison
| Tax Provision | Current Law | House Bill | Senate Bill (Approved by House) |
| IRS Direct File Program | Pilot program active. | Terminates Direct File; creates Free File task force. | Keeps Direct File; $15M for partnership study. |
| Sec. 199A QBI Deduction | 20% pass-through deduction; expires after 2025. | 23% deduction; permanent; modifies phase-out. | 20% permanent; increases phase-out threshold; adds $400 min deduction. |
| PTET SALT Deduction | $10k individual cap; PTET workaround allowed. | $40k individual cap; PTET disallowed for SSTBs. | $40k cap; no limit for pass-throughs. |
| Sec. 461(l) Excess Business Loss | Disallowed through 2028; carried forward under NOL rules. | Made permanent; adds re-testing. | Made permanent; preserves carryforward treatment. |
| Employee Retention Credit (ERC) | Claims accepted through 2024/2025; enforcement ongoing. | ERC repeal removed from final House version. | Disallows late 2021 claims as of Jan 31, 2024; enhances enforcement. |
| Childcare Credit | 25% of expenses; $150k max. | Increased to 40% (50% for small biz); $500k–$600k max; indexed. | Same as House. |
| Form 1099 Reporting Threshold | $600 threshold. | $2,000 threshold; inflation-adjusted after 2026. | Same as House. |
| Third-Party Network De Minimis | ARPA changed from $20k/200 txns to $600. | Restores $20k/200 txn threshold. | Same as House. |
| Paid Family Leave Credit | Temporary; ends after 2025. | Extended and enhanced. | Same as House. |
| R&E Expensing | 5-year amortization for domestic; 15 for foreign. | Full domestic expensing 2025–2029. | Full domestic expensing permanent; retroactive to 2022 for small businesses. |
| Bonus Depreciation | 80% in 2023, phases out by 2026. | 100% from Jan 19, 2025–2029. | 100% permanent for property acquired after Jan 19, 2025. |
| Manufacturing Property | Not separately defined. | Bonus depreciation for qualifying manufacturing property (service by 2033). | Same but must be in service by 2031. |
| Sec. 179 Expensing | $1.16M limit; $2.89M phase-out. | $2.5M limit; $4M phase-out. | Same as House. |
| Small Business Accounting | $31M gross receipts threshold (2025). | $80M threshold for manufacturers. | Not addressed. |
| Sec. 1202 Stock Exclusion | 100% exclusion if held 5+ years. | Not addressed. | 50% exclusion (3 years), 75% (4), 100% (5); increases $50M cap to $75M. |
| Sec. 163(j) Interest Deduction | EBIT through 2021; EBITDA after. | Returns to EBITDA for 2025–2029. | Returns to EBITDA permanently. |
| Tip Credit | Available for food/beverage industry. | Expanded to beauty services (2025+). | Same as House. |
| WOTC | Expires Dec 31, 2025. | Not extended. | Not extended. |
| FDII/GILTI Deduction | 37.5% FDII, 50% GILTI. | 36.5% FDII, 49.2% GILTI. | 33.34% FDII, 40% GILTI; renamed as FDDEI and NCTI. |
| BEAT | Increases to 12.5% after 2025. | Caps at 10.1%. | Caps at 10.5%. |
| UBIT Fringe Benefits | Transportation fringe disallowed under TCJA. | Tax-exempt orgs pay UBIT; exception for churches. | Not addressed. |
| Opportunity Zones | Expire end of 2028. | Ends early (2026); new round from 2027–2033 with 33% rural requirement. | Makes OZs permanent with rolling 10-year designations. |
| State Tax Nexus | Protected under P.L. 86-272 (solicitation only). | Broadens ‘solicitation’ to include facilitation. | Same as House; moved to Judiciary Title. |
| Corporate Charity Deduction | Up to 10% of taxable income. | Adds 1% floor; only amounts above deductible. | Same as House. |
Energy Key Provisions — Detailed Comparison
| Tax Provision | Current Law | House Bill | Senate Bill (Approved by House) |
| Sec. 179D (Energy Efficient Commercial Buildings Deduction) | Allows up to $5/sq.ft. for energy-efficient building systems. Phases in through 2032. | Not addressed. | Terminates for property beginning construction after June 30, 2026. |
| Sec. 25C (Nonbusiness Energy Property Credit) | 30% of qualified expenses; annual cap of $1,200; expires after 2032. | Ends after December 31, 2025. | Same as House. |
| Sec. 25D (Residential Clean Energy Credit) | 30% credit for solar, wind, geothermal; phases down after 2032 and expires in 2034. | Ends after December 31, 2025. | Same as House. |
| Sec. 25E (Used Clean Vehicle Credit) | Up to $4,000 for qualifying used EVs; income and price caps; expires in 2032. | Ends after December 31, 2025. | Ends after September 30, 2025. |
| Sec. 30C (Alternative Fuel Vehicle Refueling Property) | 30% credit; up to $100,000 per item; available through 2032. | Ends after December 31, 2025. | Ends after June 30, 2026. |
| Sec. 30D (New Clean Vehicle Credit) | Up to $7,500 for new EVs; subject to critical mineral and battery content requirements; ends in 2032. | Ends after December 31, 2025. | Ends after September 30, 2025. |
| Sec. 45D (New Markets Tax Credit) | Provides annual credit allocation through 2025. | Not addressed. | Makes NMTC permanent. |
| Sec. 45L (Energy Efficient Home Credit) | Up to $5,000 per home for qualified new energy-efficient homes; expires in 2032. | Ends after December 31, 2025 (or 2026 for homes begun before May 2025). | Ends after June 30, 2026. |
| Sec. 45W (Commercial Clean Vehicles Credit) | Credit of up to $40,000 per qualifying commercial EV; expires in 2032. | Ends after December 31, 2025. | Ends after September 30, 2025. |
| Sec. 45Y (Clean Electricity Production Credit) | New credit with no expiration; replaces existing wind/solar credits starting in 2025. | Phases out starting in 2029; transferability removed; restricts foreign entity participation. | Ends eligibility for wind/solar starting 2027; others end in 2032; same restrictions on foreign participation. |
| Sec. 48E (Clean Electricity Investment Credit) | No expiration; replaces ITC for projects starting after 2024. | Same as Sec. 45Y phaseout. | Ends after 2027 for wind/solar and after 2032 for others. |