10 May 2025

BREAKING TAX NEWS | Ways and Means Sets Reconciliation Markup with Preliminary Bill

Chairman Jason Smith (R-MO) formally announced a May 13 (at 2 p.m.) markup of the House Ways and Means Committee portion of the budget reconciliation bill to extend Tax Cuts & Jobs Act (TCJA) provisions expiring at the end of 2025 and released a limited version of his Chairman’s Mark mostly addressing TCJA extensions, with other provisions and revenue offsets likely detailed in a substitute amendment later. The preliminary legislative text does make modifications to some provisions in addition to extending them.

The preliminary mark addresses the following tax provisions:
 

  • Individual rates (10%, 12%, 22%, 24%, 32%, 35%, 37%) made permanent (with inflation relief for rates below the 37% rate)
     
  • Standard deduction extended past 2025 and increased for years 2025 - 2028
     
  • Personal exemptions reduction to $0, effectively suspending the provision, is made effective after 2025
     
  • Child tax credit increased further to $2,500 for 2025 - 2028 and subject to an added Social Security number requirement, and makes permanent the maximum amount of the additional child tax credit per qualifying child of $1,400 adjusted for inflation ($1,700 in 2025)
     
  • 199A pass-through deduction made permanent, increased to 22%, and made applicable to certain interest dividends of qualified business development companies
     
  • Estate tax exemption permanently set at $15 million (inflation adjusted)
     
  • AMT exemption amounts and phase-out thresholds extended past 2025
     
  • $750,000 ($375,000 for married filing separately) limitation on home mortgage acquisition indebtedness is made permanent, and the exclusion of interest on home equity indebtedness from the definition of qualified residence interest made permanent
     
  • Personal casualty loss limitation made permanent
     
  • Repeal of miscellaneous itemized deductions made permanent
     
  • Permanent repeal of Pease limitation
     
  • Termination of the exclusion for qualified bicycle commuting reimbursement after 2025
     
  • Permanent repeal of the deduction for moving expenses, except for a member of the Armed Forces
     
  • Wagering losses deduction clarification to include deductible expenses incurred in carrying on the gambling activity extended beyond 2025
     
  • Makes permanent certain provisions related to ABLE accounts and eligibility for the Saver’s Credit
     
  • Restores the exclusion from an individual’s gross income for an otherwise includible amount from the discharge of a qualifying loan on account of a student’s death or total and permanent disability
     
  • Makes permanent the current rates on global intangible low-taxed income (GILTI) of a 50% deduction (10.5% rate), including the corresponding section 78 gross-up amount, and foreign-derived intangible income (FDII) of a 37.5% deduction (13.125% rate)
     
  • Makes permanent the current rates for the base erosion and anti-abuse tax (BEAT) of 10%, or 11% for banks/dealers, and repeals the post-2025 change that would reduce regular tax liability (and increase the base erosion minimum tax amount) by the taxpayer’s income tax credits for the taxable year
     

The Joint Committee on Taxation description (JCX-18-25) has been released and is available here

Document ID: 2025-9004