{"id":5179,"date":"2025-07-08T20:14:15","date_gmt":"2025-07-08T20:14:15","guid":{"rendered":"https:\/\/patellawoffices.com\/blog\/?p=5179"},"modified":"2025-07-08T20:16:17","modified_gmt":"2025-07-08T20:16:17","slug":"winners-and-losers-in-the-one-big-beautiful-bill-act-a-tax-lawyers-perspective","status":"publish","type":"post","link":"https:\/\/patellawoffices.com\/blog\/planning-for-tax-minimization\/winners-and-losers-in-the-one-big-beautiful-bill-act-a-tax-lawyers-perspective\/","title":{"rendered":"Winners and Losers in the \u201cOne Big Beautiful Bill Act\u201d: A Tax Lawyer\u2019s Perspective"},"content":{"rendered":"\n<p>The \u201cOne Big Beautiful Bill Act,\u201d the latest legislative achievement of the current Trump administration, brings major changes to the tax code and broader economic policy. Its impact spans a wide range of industries and taxpayers. As a tax lawyer, I reviewed the new law to identify the primary beneficiaries and those adversely affected under the new law, with a focus on tax implications.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Winners<\/h3>\n\n\n\n<p><strong>High-Net-Worth Individuals and Estates<\/strong><br>The legislation significantly increases the federal estate tax exemption to $15 million per individual ($30 million per married couple), indexed for inflation. This permits ultra-high-net-worth individuals to transfer substantially more wealth without incurring estate tax liability. In addition, the individual income tax rate cuts enacted under the 2017 Tax Cuts and Jobs Act are made permanent, disproportionately benefiting top earners.<\/p>\n\n\n\n<p><strong>Residents of High-Tax States<\/strong><br>The cap on the state and local tax (SALT) deduction is temporarily raised to $40,000 annually through 2029, providing significant relief for taxpayers in states with high property or income taxes. However, the cap phases out for those with incomes exceeding $500,000, and reverts to the $10,000 limit thereafter.<\/p>\n\n\n\n<p><strong>Owners of Pass-Through Businesses<\/strong><br>The qualified business income (QBI) deduction under IRC \u00a7199A, originally scheduled to sunset in 2025, is made permanent. Eligible pass-through entities\u2014including sole proprietorships, partnerships, and S corporations\u2014may continue to deduct up to 20% of qualified income, subject to applicable wage and capital limitations.<\/p>\n\n\n\n<p><strong>Automobile Dealers<\/strong><br>The legislation introduces a new deduction allowing up to $10,000 of annual loan interest on U.S.-manufactured automobiles to be deducted through 2028. The deduction is phased out for higher-income earners ($100,000 for single filers; $200,000 for joint filers), providing a potential incentive to purchase domestically-produced vehicles.<\/p>\n\n\n\n<p><strong>Manufacturing &amp; Research Sectors<\/strong><br>Immediate expensing for domestic research and development costs has been permanently reinstated. Small businesses with gross receipts of $31 million or less are allowed to retroactively expense research and development expenditures incurred after December 31, 2021. These changes were welcomed by manufacturers and are expected to spur capital investment and research.<\/p>\n\n\n\n<p><strong>Elderly and Tipped Wage Workers<\/strong><br>Taxpayers aged 65 and older receive an increased standard deduction. In addition, income from tips and overtime pay is excluded from taxable income through 2028, albeit subject to expiration and fiscal limitations.<\/p>\n\n\n\n<p><strong>Families with Children<\/strong><br>The child tax credit increases by $200 (to $2,200 per child) starting in 2025, and is indexed to inflation thereafter. A new provision permits eligible families to establish new \u201cTrump Accounts\u201d with a $1,000 deposit for children born between 2025 and 2028.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">LOSERS<\/h3>\n\n\n\n<p><strong>Low-Income Households<\/strong><br>To offset the bill\u2019s cost, reductions are made to social safety net programs. Medicaid eligibility becomes contingent on expanded work requirements, except for the elderly, disabled, or caregivers of young children. Food assistance under SNAP (food stamps) is also curtailed, extending work requirements to age 65 and requiring states to contribute toward benefits beginning in 2028.<\/p>\n\n\n\n<p><strong>Renewable Energy Sector<\/strong><br>Several tax incentives enacted under the prior administration\u2019s climate legislation are repealed or phased out. This includes the investment and production tax credits for solar and wind projects, as well as residential energy efficiency credits. <\/p>\n\n\n\n<p><strong>Electric Vehicle Manufacturers<\/strong><br>The consumer tax credit of up to $7,500 for electric vehicle purchases is eliminated, adversely affecting manufacturers such as Tesla and General Motors and potentially slowing EV adoption.<\/p>\n\n\n\n<p><strong>Private Universities with Large Endowments<\/strong><br>The excise tax on university endowments is increased significantly, with a new progressive rate structure reaching up to 8% for institutions with the highest endowment income per student. The measure targets elite private universities and is part of a broader campaign against perceived institutional privilege.<\/p>\n\n\n\n<p><strong>Immigrants<\/strong><br>The new law imposes a 1% tax on remittances\u2014money transfers to foreign countries\u2014which disproportionately impacts lower-income and new immigrants sending support to family abroad. <\/p>\n\n\n\n<p><strong>Gamblers<\/strong><br>Gambling losses are deductible only up to 90% of winnings, rather than on a dollar-for-dollar basis. This could result in tax liability even when a taxpayer&#8217;s net gambling result is a loss.<\/p>\n\n\n\n<hr class=\"wp-block-separator has-alpha-channel-opacity\"\/>\n\n\n\n<p>The \u201cOne Big Beautiful Bill Act\u201d marks a profound shift in federal tax and fiscal policy, with major implications for estate planning, pass-through entities, multinational corporations, and individuals across income brackets. With some winners and losers, tax professionals should carefully evaluate the Act\u2019s impact on clients and consider proactive planning in light of these substantial changes.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>The \u201cOne Big Beautiful Bill Act,\u201d the latest legislative achievement of the current Trump administration, brings major changes to the tax code and broader economic policy. Its impact spans a wide range of industries and taxpayers. As a tax lawyer, I reviewed the new law to identify the primary beneficiaries and those adversely affected under [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_daextam_enable_autolinks":"1","_monsterinsights_skip_tracking":false,"_monsterinsights_sitenote_active":false,"_monsterinsights_sitenote_note":"","_monsterinsights_sitenote_category":0,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-5179","post","type-post","status-publish","format-standard","hentry","category-planning-for-tax-minimization"],"_links":{"self":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/5179","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/comments?post=5179"}],"version-history":[{"count":2,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/5179\/revisions"}],"predecessor-version":[{"id":5185,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/5179\/revisions\/5185"}],"wp:attachment":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/media?parent=5179"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/categories?post=5179"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/tags?post=5179"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}