Tax heights from the one large, beautiful bill Harris Beach Murtha Pllc

The highly awaited text of the one large beautiful Bill Act (the “Obbb”) was published at the beginning of the last week. It will certainly do justice to part of its name on more than 1,110 pages. By Friday, several groups of the Republicans of the Republicans were already in question of his beauty when the legislation did not come out of the household committee of the house.

The household committee teamed up again last night and advanced the legislation with the Freedom Kaucus members, who were “present” after “No” on Friday.

State and local tax deduction: not salty enough

According to applicable law, taxpayers can deduct up to 10,000 US dollars to state and local taxes. The OBBB would earn 30,000 US dollars to the Salzkappen, with a gradual expression for taxpayers with more than $ 400,000 modified adjusted gross income. The invoice also limits the throughout the passage tax (“Ptet”), which the blue states developed after reducing the salt cap in 2017.

The “Salz Caucus”, which includes members of Republicans in New York and California, is dissatisfied with the proposed upper limit of $ 30,000. Rep. Mike Lawler (NY) previously introduced an invoice to increase the salt cap to $ 100,000 for individuals and $ 200,000 for married couples. It seems unlikely that these borders would make it to OBBB, but with a razor -thin margin in the house, the Republicans cannot afford to lose voices.

At the same time, increasing the salt cap is one of the most expensive tax cuts, which leads to disagreement among the Republicans from Red States, especially the Caucus of the House Freedom. The joint tax committee estimates a loss of government income of almost 200 billion US dollars a year from the 2027 financial year if the unlimited salt deduction was to return. The Republicans have to thread the needle and satisfy the duel factions within the party in order to make the great beautiful bill into a law.

International tax: new retaliation measures

The United States has the success with the threat of a “stick” to make foreign companies create their offers. Above all, the law on compliance with abroad Compliance Act (FATCA), which threatened the introduction of a 30% withholding tax on the US source income of foreign companies that did not open their US owners or account holders (which may have avoided US tax). The OBBB would provide the financial department a new instrument to combat an “unfair foreign tax”.

An “unfair foreign tax” includes a granted profit rule, digital service tax, the profit tax and “any other tax levied with a public or specified purpose, which indicates that the tax is disproportionately supported by the US persons.

In the case of retaliation against a “discriminatory foreigner”, the United States would increase the US tax rate for individuals and companies in this abroad. The retaliation tax rates would start with an increase of 5% compared to the relevant power and could increase over four years (in 5%) to an additional 20%. These new measures could therefore mean that US taxes on dividends, interest, rents, rents, rents, rents, etc. in the USA can ultimately increase from currently 30% to 50%. It is probably the goal of this new regime to enable the United States to influence a foreign country that imposes an “unfair foreign tax” for rethinking.

Otherwise, OBBB maintains the current treatment of intangible intangible foreigners (FDII), global intangible low income (GILTI) and the basic erosion and anti-abuse tax (beat).

Bonus depreciation: revitalized

The OBBB restores the 100% bonus depreciation for certain qualified property, which was put into service on the inauguration day of President Trump (January 20, 2025) and before January 1, 2030. According to the current law, which was implemented by the law on tax reductions and jobs, taxpayers may only deduct 40% of the qualified property committed in 2025.

The OBBB also significantly improves the depreciation of certain new factories. According to applicable law, it is not written off over a period of 39 years as part of a period of time. OBBB would enable a complete and immediate deduction of the costs for “qualified production ownership”. The property must be involved in the production, production or refinement of material personal property. This provision seems to be the dangling carrot that would work in connection with the US tariffs to attract the localization of factories within the United States.

Green tax credits: targeted

The OBBB stops fighting the law on reducing inflation, but accelerates the course of many of its “green” tax credits. For example, the tax credit for electric vehicles, energy -efficient self -improvement loans, the loans for cleaning energy and the tank -like property tax credit for fuel vehicles would end at the beginning of the year at the end of 2025.

The calculation phases (from 2027) also a removal of the transferability of the Cred Electricity Production Credits (45y (a)), the Cred Electricity Investment Credit (48e), the Credit Credit Credit Cred (45z (a)), the credit for carbon oxide sequestration (45q (A))) Zero emission core power production loan (45).

From the Freedom Caucus there is indications that the OBBB comes closer to a complete elimination of all IRA tax credits. The OBBB can be revised to wait for additional tax credits for the early termination or restrictions for the transmission capacity.

Opportunity zones: another round

The OBBB would renew the program for Opportunity Zone by making new opportunities zone investments after 2026. Every profit that was set up in the new round would be recorded at the end of 2033. New investments made in 2027 or 2028 can also qualify for a 10% discount discount for a discount of 10% in order to be recognized in the second round in investments for investments in the possibilities for the possibilities in Rural qualification. There are no obvious changes to the current investors in a qualified opportunity fund (i.e. the profit is still being recognized at the end of 2026).