E.J. Callahan & Associates LLC
By Jeffrey T. Rogers, CPA, MST | Partner, E.J. Callahan & Associates

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (“OBBBA”) into law. The package contains an estimated $12.5 trillion in tax provisions that will impact both businesses and individuals. The provisions of the bill largely fell into one of four categories:
- Addressing provisions of the Tax Cuts and Jobs Act (“TCJA”) that were due to expire
- “Fixing” provisions put in place to pay for the TCJA that were largely detrimental to taxpayers
- Fulfilling promises made along the presidential campaign trail
- Introducing tax measures to pay for the OBBBA tax benefits
TCJA: Expiring/Returning Provisions
The TCJA was enacted in 2017 during Trump’s first term in office. Due to its passage through a budgetary process called “reconciliation”, many of the provisions in the bill were required to have an expiration date which, in nearly all cases, was set to be December 31, 2025. Without Congressional action tax law would effectively return to its pre-TCJA form at the end of the year which would mean expiration and adjustment of many popular tax breaks.
Below is a look at how the OBBBA addressed this situation.
Individual Income Tax Rates:
The TCJA introduced seven inflation-adjusted tax brackets that were set to return to their pre-2018 ranges. The OBBBA has made these tax rates permanent with continued inflation indexing post-2025.
Standard Deduction:
The TCJA approximately doubled the standard deduction that all taxpayers are able to utilize to reduce their taxable income. Doing so minimized the need to itemize deductions which, in general, aided lower income taxpayers. The OBBBA permanently extended the standard deduction and, for 2025 set them at $15,750 for individuals and $31,500 for married filed joint filers.
Perhaps recognizing that a higher standard deduction could lower incentive to donate to charity, the OBBBA enacted a provision allowing taxpayers who do not itemize to deduct up to $1,000 in contributions, $2,000 if married filing jointly.
Child Tax Credit:
Prior to the TCJA, the credit was equal to $1,000 per child with many taxpayers unable to benefit due to a low income phase-out threshold. The TCJA doubled the credit (to $2,000) and increased the phaseout threshold to $200,000 individual and $400,000 joint. The OBBBA made the higher phaseout thresholds permanent while increasing the per child credit to $2,200 with future adjustments for inflation.
Estate and Gift tax exemption:
The estate and gift tax exemption determines how much of a decedent’s estate will be taxed before passing to non-spouse beneficiaries. The TCJA doubled the exemption levels with annual inflation adjustments allowing it to reach $13.61 million for both spouses in 2024. The OBBBA increased the exemption to $15 million and made the higher levels permanent.
Section 199A Pass-Through Entity Qualified Business Income Deduction:
Business owners may remember that reducing the corporate tax rate from 35% to 21% was the primary focus of the TCJA. This deduction, set at 20% of qualified income, was put into effect to level the playing field between corporations and pass-through entities, which are taxed at individual tax rates. While the corporate rate had been made permanent, the Section 199A deduction was due to expire, which would have been devastating to small and mid-size businesses. The OBBBA made the deduction permanent. At one point there was a proposal to increase the deduction rate to 23% but that ultimately did not come to fruition, and it will remain at its current 20% into the future.
Not everything related to the expiring TJCJA provisions was welcome news. Had the enacted law run its course and pre-TCJA provisions returned, taxpayers would have seen the return of the personal exemption deduction and had the ability to deduct moving expenses, miscellaneous itemized deductions, and a larger portion of their home mortgage and home equity indebtedness.
Provision Fixes
When the TCJA was enacted, there were tax provisions put in place that would offset or pay for some of the tax benefits. To various degrees, all of these had negative effects on taxpayers and, as a result, a goal of the OBBBA was to alleviate some of the burden that had been created.
Fixed Asset Depreciation Expensing:
As part of the TCJA, businesses were permitted to write off the full cost of qualified capital assets in the year placed in service under a provision called “Bonus depreciation”. Prior to the TCJA, the bonus depreciation rate was set at 50%. The ability to write off 100% in the first year was only effective through 2022. Beginning in 2023, the first year write off was capped at 80% of the cost with every subsequent year seeing an additional 20% reduction until phased out in 2027.
The OBBBA restored bonus depreciation for qualified property placed in service after January 19, 2025.
In addition, with its increase to $2.5 million, the OBBBA effectively doubled the first-year expensing allowed by Section 179, which is similar in concept to bonus depreciation but with more federal limitations. The OBBBA loosened one of the limitations in that companies can take full benefit of Section 179 if eligible asset acquisitions did not exceed $4 million for the year.
Return to Section 163(j) Business interest expense limitation to EBITDA:
One of the objectives of the TCJA was for businesses to reduce their reliance on debt to fund operations. In an attempt to accomplish this, unless limited exceptions applied or certain elections were made, section 163(j) of the Internal Revenue Code was expanded to require most company’s interest expense deduction to be limited to 30% of their adjusted taxable income. Any excess interest expense could be carried forward to a future tax year and used when the company had “excess business income”. Many companies were able to avoid a deduction limitation through 2021 as the adjusted taxable income figure was determined prior to a reduction for tax depreciation and amortization expense. However, the calculation changed in 2022, as scheduled by the TCJA, such that the adjusted taxable income threshold became post-depreciation and amortization expense. This change, coupled with rising interest rates, resulted in significantly more suspended interest expense across businesses. While the OBBBA did not repeal the Section 163(j) limitation, it did return to its pre-2022 calculation, which was based on EBITDA.
Repeal of the Section 174 requirement to amortize Domestic R & E expenditures:
Historically, Section 174 of the Internal Revenue Code had permitted an immediate deduction of research & experimentation expenses. However, as part of the TCJA, Section 174 was amended and, beginning in 2022, the ability to deduct was changed to a requirement to capitalize and amortize domestic research & experimentation expenses over 5 years (15 years for international R&E expenses). The capitalization requirement went into effect regardless of whether a company claimed the Section 41 Research & Development tax credit and led to several small and mid-sized businesses having significantly higher tax bills in 2022-2024 than they had seen previously.
While foreign R&E is still required to be amortized over 15 years, the OBBBA will allow full expensing to return for domestic R&E beginning in 2025. Eligible small businesses will be able to amend their 2022-2024 returns to recover their unamortized R&E expenses and larger businesses may opt to deduct their remaining costs in 2025 and/or 2026
Repeal of State and Local Tax (SALT) Cap Limitation:
Prior to the TCJA, individual taxpayers were generally able to deduct the full amount that they paid for state income taxes, real estate taxes and certain personal property taxes as an itemized deductions on the personal tax returns. The TCJA placed a $10,000 cap on the amount able to be deducted.
While those in high taxing jurisdictions had hoped for an outright repeal, that did not come to pass. However, the OBBBA did increase the cap to $40,000 in 2025 with annual 1% increases through 2029 before returning to $10,000 in 2030. The deduction would be subject to phasedown beginning with modified adjusted gross income of $500,000 but would not be reduced below $10,000.
On a related note, there had been some concern that the Pass-through entity tax (PTET) workaround that many states had administered over the last 3-4 years would be adversely impacted by this SALT cap increase. An earlier version of the OBBBA was calling for the pass-through entity taxes to be included among the $40,000. However, that potential restriction did not make it into the final bill.
Campaign Trail Promises
While campaigning for office prior to the election, Trump raised several tax-related ideas that didn’t have historical precedence in the tax code. The most notable were:
No tax on tip income:
The OBBBA introduced a deduction that would be available through 2028 for up to $25,000 of qualified tips received from working in certain customarily tipped industries. The tips must be reported in income and may be subject to state or payroll taxes but may be deducted federally - even by non-itemizers. The deduction will begin to phase out for individuals who make $150,000 and would be completely phased out if making more than $160,000.
No tax on overtime:
Very similar to the “no tax on tip income”, the no tax of overtime will provide a $12,500 deduction to single taxpayers and $25,000 to married taxpayers. Overtime compensation is defined as the amount paid in excess of an employee’s regular rate and only that portion would be deductible. This phaseout range for an individual is $150,000-$275,000 of income.
No tax on social security benefits:
While the original intention was to eliminate tax on social security benefits, this is also taking the form of a deduction. Regardless of whether social security benefits are received, all seniors aged 65 or over will be entitled to a $6,000 deduction. This is over and above the $1,600 deduction that a senior aged 65 or older may add to their standard deduction. There is a phaseout at higher earning levels.
Deduction for car loan interest:
Intended to encourage the purchase of vehicles assembled in the US, taxpayers with income under $100,000 ($200,000 if married filing jointly) may deduct up to $10,000 in interest on loans secured by the vehicle through 2028.
Bonus Depreciation for Qualified Production Property:
A central theme in Trump’s platform was to bring manufacturing jobs back to the US. To aid in that endeavor, bonus depreciation will be allowed on the manufacturing property costs where production begins after January 19, 2025 and before 2029. The manufacturing property must be placed in service before 2031.
Introducing tax measures to pay for the OBBBA tax benefits
Clean Energy Incentives:
Many of the clean energy credits and deductions that were introduced or expanded as part of the Inflation Reduction Act will see an acceleration of their termination dates. Credits for Energy Efficient Home Improvement, Residential Clean Energy, New, Previously Owned, and Commercial Clean Vehicles will not be available for 2026 purchases and, in some cases, sooner.
The Section 179D, Energy Efficient Commercial Buildings Deduction and Section 45L New Energy Efficient Home Credit have slightly longer shelf lives running through June 30, 2026.
Credits for wind and solar facilities placed in service after 2027 will not be available.
Limitation of Charitable Contribution Deductibility:
Corporations have always been limited by a ceiling equal to 10% of taxable income; now there will be a 1% floor as well. Individual taxpayers who itemize will have a floor of their own equal to .5% of their adjusted gross income.
Limitation on Deductibility of Gambling Losses:
Prior to the passing of the OBBBA, taxpayers with gambling winnings could fully offset those earnings with the gambling losses that they incurred. Now gambling losses may only shelter 90% of the gambling earnings.
Excess Business Loss Limitations:
Originally enacted as part of the Tax Cuts and Jobs Act, this loss limitation under Sec. 461(l) has the effect of limiting the amount of business loss that can be deducted in a given year. Such losses get converted to Net Operating Losses and become available for use in future years subject to NOL limitations. Set to expire at the end of 2028, the OBBBA made this loss limitation permanent.
Termination of Employee Retention Credit (ERC) program:
The ERC program had already reached its end date for new claims as a result of the 3-year statute of limitation. However, now the OBBBA has announced that any claims submitted after January 31, 2024, which would have been timely, will not be considered either.
Other Notable Tax Provisions
The OBBBA contained additional tax provisions that didn’t fit into one of the above four categories but were important, nonetheless. Opportunity Zones, New Market Tax Credits, and International tax rates were all addressed in the bill. The payment threshold for Form 1099 reporting more than tripled to $2,000 and Section 1202, Qualified Small Business Stock, saw significant enhancement that will definitely need to be taken into consideration when evaluating choice of entity.
One thing is clear: there are many aspects of this bill that could warrant discussion with a qualified professional. Should you have questions with anything contained within the OBBBA bill and how it may impact your personal or business tax situation, feel free to reach out to an EJC partner.