PlainBillCongress, translated.Legislation. Context. Public interest.Congressional Research Service
Version 00 · Introduced in House · Jan 3, 2025
TCJA Permanency Act
This bill makes permanent multiple federal tax provisions enacted in 2017 by the Tax Cuts and Jobs Act.
The bill makes permanent the
Showing the opening paragraphs of the official summary.
individual tax rates of 10%, 12%, 22%, 24%, 32%, 35%, and 37%;
increased standard deduction;
personal exemption allowance repeal;
exclusion from income of student loans discharged due to death or disability;
qualified business income tax deduction (199A tax deduction);
allowance of ABLE account contributions in excess of the annual gift tax exclusion amount;
base estate and gift tax exclusion amount of $10 million (adjusted annually); and
alternative minimum tax exemption and phaseout amounts for noncorporate taxpayers.
The bill makes permanent the child tax credit amounts of $2,000 per child and $500 for dependents, the $200,000 phaseout threshold ($400,000 for joint filers), and the refundable portion of the tax credit.
The bill expands the expenses eligible for tax-free withdrawals from qualified tuition plans (529 plans) to include additional expenses associated with homeschool and elementary and secondary schools (e.g., instructional materials, tutoring, test and enrollment fees, and educational therapies).
The bill permanently eliminates certain miscellaneous itemized deductions and makes permanent the
state and local tax deduction limit of $10,000 ($5,000 for married individuals filing separately),
mortgage interest tax deduction limit of $750,000 ($375,000 for married individuals filing separately),
limit on the deduction of cash charitable contributions to 60% of a taxpayer’s adjusted gross income, and
certain limits on casualty loss tax deductions.
The bill also permanently eliminates the exclusion from income for employer-reimbursed bicycle commuting expenses.
People & committees
Rep. Buchanan, Vern [R-FL-16] · R–FL
Legislative record
A procedural vote is different from passage. Passage in one chamber does not establish enactment. Explore the glossary.
Referred to the House Committee on Ways and Means.
Introduced in House
Introduced in House
Primary sources
Text links open the official source. We also preserved the text version used in the PlainBill explanation below.
Source last updated: Sep 19, 2026. Consult Congress.gov for the current record.
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PlainBill explanation
Based on the full Introduced in House · 2025-01-03 text. This explanation has not received human editorial review. This overview describes the proposal’s major provisions; it does not establish what its real-world effects would be.
The proposed TCJA Permanency Act would keep many tax changes in place without their existing end dates. It would set income-tax rates, provide credits for qualifying children and other dependents, and continue restrictions on several deductions. It would also expand eligible education-account expenses and change rules affecting business losses, disability accounts, military moves, estates, and gifts. These are proposed changes; the supplied record does not establish enactment.
This Act may be cited as the TCJA Permanency Act.
(1) $2,000 for each qualifying child of the taxpayer, and (2) $500 for each qualifying dependent (other than a qualifying child) of the taxpayer.
In the case of an individual, miscellaneous itemized deductions shall not be allowed.
Sec. 101. Modification of rates.
Sec. 112. Limitation on losses for taxpayers other than corporations.
Sec. 124. Increased contributions to ABLE accounts.
Sec. 132. 529 account funding for homeschool and additional elementary and secondary expenses.
Sec. 149. Deduction for moving expenses limited to members of Armed Forces.
Sec. 151. Increase in estate and gift tax exemption.
Source snapshot updated 2026-09-19T23:07:26Z. 2025-01-03: Referred to the House Committee on Ways and Means. 2025-01-03: Introduced in House
Section 101 would replace the income-tax tables for each filing category. For example, the joint-return table would apply progressively higher rates of 10%, 12%, 22%, 24%, 32%, 35%, and 37% to successive portions of taxable income. Its listed dollar boundaries would be adjusted for inflation, so they are not fixed future-year thresholds.
(a) Married individuals filing joint returns and surviving spouses Section 1(a) is amended by striking the table contained therein and inserting the following: If taxable income is: The tax is: Not over $19,050 10% of taxable income. Over $19,050 but not over $77,400 $1,905, plus 12% of the excess over $19,050. Over $77,400 but not over $165,000 $8,907, plus 22% of the excess over $77,400. Over $165,000 but not over $315,000 $28,179, plus 24% of the excess over $165,000. Over $315,000 but not over $400,000 $64,179, plus 32% of the excess over $315,000. Over $400,000 but not over $600,000 $91,379, plus 35% of the excess over $400,000. Over $600,000 $161,379, plus 37% of the excess over $600,000.
(b) Heads of households Section 1(b) is amended by striking the table contained therein
(c) Unmarried individuals other than surviving spouses and heads of households Section 1(c) is amended by striking the table contained therein
(d) Married individuals filing separate returns Section 1(d) is amended by striking the table contained therein
by increasing the minimum and maximum dollar amounts for each bracket for which a tax is imposed under such table by the cost-of-living adjustment for such calendar year
Estates and trusts would have income-tax rates of 10%, 24%, 35%, and 37%. Section 101 would also specify separate income boundaries for capital-gains rates, with inflation adjustments. The listed maximum 15% rate amounts would be $479,000 for joint returns or surviving spouses, half that for married separate returns, $452,400 for heads of household, $425,800 for other individual filers, and $12,700 for estates and trusts.
(e) Estates and trusts Section 1(e) is amended by striking the table contained therein and inserting the following: If taxable income is: The tax is: Not over $2,550 10% of taxable income. Over $2,550 but not over $9,150 $255, plus 24% of the excess over $2,550. Over $9,150 but not over $12,500 $1,839, plus 35% of the excess over $9,150. Over $12,500 $3,011.50, plus 37% of the excess over $12,500.
(12) Maximum 15-percent rate amount defined For purposes of this subsection, the maximum 15-percent rate amount shall be— (A) in the case of a joint return or surviving spouse (as defined in section 2(a)), $479,000 (½ such amount in the case of a married individual filing a separate return), (B) in the case of an individual who is a head of household (as defined in section 2(b)), $452,400, (C) in the case of any other individual (other than an estate or trust), $425,800, and (D) in the case of an estate or trust, $12,700.
(14) Inflation adjustment (A) In general Each of the dollar amounts in paragraphs (12) and (13) shall be increased by an amount equal to— (i) such dollar amount, multiplied by (ii) the cost-of-living adjustment determined under subsection (f)(3)
The rate changes would apply to tax years beginning after enactment. Section 101 would also limit the opening rule of tax-code section 15 to corporations and prevent that section from applying to rate changes made by this bill. The underlying section 15 calculation rules are not reproduced.
Subsection (a) of section 15 is amended by striking If any rate of tax and inserting In the case of a corporation, if any rate of tax.
(j) Effective date (1) In general The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act. (2) Application of section 15 Section 15 of the Internal Revenue Code of 1986 shall not apply to any change in a rate of tax by reason of— (A) section 1(j) of such Code (as in effect before its repeal by this section), or (B) any amendment made by this Act.
Section 111 would delete subsection (i) of the qualified-business-income deduction statute, beginning with tax years starting after enactment. Because the deleted subsection and the deduction formula are not reproduced, this source alone does not establish the deduction's percentage or complete eligibility rules.
111. Deduction for qualified business income (a) In general Section 199A is amended by striking subsection (i). (b) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
For taxpayers other than corporations, section 112 would disallow an 'excess business loss' for the tax year without stating an end date. This does not mean every business loss would be denied: the definition of an excess business loss is not supplied. The change would apply to tax years beginning after enactment.
In the case of a taxpayer other than a corporation, any excess business loss of the taxpayer for the taxable year shall not be allowed.
(c) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 121 would replace two statutory standard-deduction amounts with $18,000 and $12,000 and adjust them for inflation using 2017 as the reference year. Section 141 would also write additional deductions of $600 for age 65 or older and $600 for blindness into the statute, subject to the bill's inflation adjustment; those are base amounts, not final future-year amounts. On joint returns, the age and blindness rules would apply separately to each spouse.
Section 63(c)(2) is amended— (1) by striking $4,400 in subparagraph (B) and inserting $18,000, and (2) by striking $3,000 in subparagraph (C) and inserting $12,000.
Each dollar amount in paragraph (2)(B), (2)(C), or (5) or subsection (f) shall be increased by an amount equal to— (i) such dollar amount, multiplied by (ii) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting for 2016 in subparagraph (A)(ii) thereof— (I) in the case of the dollar amounts contained in paragraph (2)(B) or (2)(C), 2017, (II) in the case of the dollar amounts contained in paragraph (5)(A) or subsection (f), 1987
the additional standard deduction is, with respect to a taxpayer for a taxable year, the sum of— (A) $600 if the taxpayer has attained age 65 before the close of such taxable year, and (B) $600 if the taxpayer is blind as of the close of such taxable year. (2) Application to married individuals (A) Joint returns In the case of a joint return, paragraph (1) shall be applied separately with respect to each spouse.
Section 122 would allow a $2,000 credit per qualifying child and $500 per other qualifying dependent. Children would have to be under 17 at the specified year-end and have their name and qualifying Social Security number listed on the return. Other dependents would need their name and taxpayer identification number listed. The credit would shrink by $50 for each $1,000, or fraction of $1,000, of modified adjusted gross income above $400,000 for joint returns or $200,000 for other returns.
(1) $2,000 for each qualifying child of the taxpayer, and (2) $500 for each qualifying dependent (other than a qualifying child) of the taxpayer.
The amount of the credit allowable under subsection (a) shall be reduced (but not below zero) by $50 for each $1,000 (or fraction thereof) by which the taxpayer's modified adjusted gross income exceeds $400,000 in the case of a joint return ($200,000 in any other case).
(1) Qualifying child The term qualifying child means any qualifying dependent of the taxpayer— (A) who is a qualifying child (as defined in section 7706(c)) of the taxpayer, (B) who has not attained age 17 at the close of the calendar year in which the taxable year of the taxpayer begins, and (C) whose name and social security number are included on the taxpayer’s return of tax for the taxable year.
The term qualifying dependent means any dependent of the taxpayer (as defined in section 7706 without regard to all that follows resident of the United States in section 7706(b)(3)(A)) whose name and TIN are included on the taxpayer’s return of tax for the taxable year.
For the refundable portion of the child credit, the bill would use a $1,400 child amount, exclude the $500 other-dependent credit, and replace $3,000 with $2,500 in the earned-income limitation provision. Inflation increases to $1,400 would be rounded down to $100 increments and capped at $600. The taxpayer's identification number and the child's qualifying Social Security number would have to be issued by the return's due date. Section 122 would also delete section 24 subsections (i), (j), and (k) and section 7527A, whose underlying provisions are not reproduced. These changes would apply to tax years beginning after enactment.
(i) by substituting $1,400 for $2,000 in subsection (a)(1), (ii) without regard to subsection (a)(2)
(2) Modification of limitation based on earned income Section 24(d)(1)(B)(i) is amended by striking $3,000 and inserting $2,500.
(B) Rounding If any increase under subparagraph (A) is not a multiple of $100, such increase shall be rounded to the next lowest multiple of $100. (C) Limitation The amount of any increase under subparagraph (A) (after the application of subparagraph (B)) shall not exceed $600.
No credit shall be allowed under this section if the identifying number of the taxpayer was issued after the due date for filing the return of tax for the taxable year.
a social security number issued to an individual by the Social Security Administration, but only if the social security number is issued— (A) to a citizen of the United States or pursuant to subclause (I) (or that portion of subclause (III) that relates to subclause (I)) of section 205(c)(2)(B)(i) of the Social Security Act, and (B) on or before the due date of filing such return.
(c) Repeal of certain later enacted provisions (1) Section 24 is amended by striking subsections (i), (j), and (k). (2) Chapter 77 is amended by striking section 7527A
(d) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 123 would allow deductions for cash donations to qualifying organizations up to 60% of the taxpayer's statutory 'contribution base,' reduced by donations allowed under another specified rule. Excess qualifying cash donations could be carried forward for the next five years. The bill would coordinate this rule with other donation limits and apply it to contributions in tax years beginning after enactment.
Any contribution of cash to an organization described in subparagraph (A) shall be allowed to the extent that the aggregate of such contributions does not exceed 60 percent of the taxpayer’s contribution base for the taxable year, reduced by the aggregate amount of contributions allowable under subparagraph (A) for such taxpayer for such year.
such excess shall be treated (in a manner consistent with the rules of subsection (d)(1)) as a charitable contribution to which clause (i) applies in each of the 5 succeeding years in order of time.
(b) Coordination with limitations on other contributions (1) Coordination with 50 percent limitation
(2) Coordination with 30 percent limitation
The amendments made by this section shall apply to contributions made in taxable years beginning after the date of the enactment of this Act.
Sections 124 and 125 would remove January 1, 2026 cutoffs from specified ABLE disability-account rules: additional contributions from an account holder's compensation, the account holder's saver’s credit, and transfers from 529 education accounts to ABLE accounts. Section 124 would apply to tax years beginning after enactment; section 125 would apply to distributions after enactment. Existing contribution amounts and transfer conditions are not reproduced.
124. Increased contributions to ABLE accounts (a) Increase in limitation for contributions from compensation of individuals with disabilities Section 529A(b)(2)(B)(ii) is amended by striking before January 1, 2026. (b) Allowance of saver’s credit for ABLE contributions by account holder Section 25B(d)(1)(D) is amended by striking made before January 1, 2026,. (c) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
125. Rollovers to ABLE programs from 529 programs (a) In general Section 529(c)(3)(C)(i)(III) is amended by striking before January 1, 2026,. (b) Effective date The amendments made by this section shall apply to distributions after the date of the enactment of this Act.
Section 126 would expressly add Egypt's Sinai Peninsula to the geographic treatment in tax-code section 112. The treatment would apply to service there only during periods when at least one U.S. Armed Forces member is entitled to hostile-fire or imminent-danger special pay for service in that area. It would cover services performed on or after enactment. The underlying section 112 rules are not fully reproduced.
Section 112(c)(2) is amended— (1) by striking means any area and inserting means— (A) any area , and (2) by striking the period at the end and inserting , and (B) the Sinai Peninsula of Egypt.
such service is performed during any period with respect to which one or more members of the Armed Forces of the United States are entitled to special pay under section 310 of title 37, United States Code (relating to special pay; duty subject to hostile fire or imminent danger), for service performed in such area.
The amendments made by this section shall apply with respect to services performed on or after the date of the enactment of this Act.
Section 131 would move the cutoff in an existing student-loan discharge rule from January 1, 2026 to January 1, 2025. For debts canceled after December 31, 2024, it would exclude from an individual's gross income qualifying student and private education loans canceled under the listed federal provisions or because of the student's death or total and permanent disability. The complete earlier discharge rule is not supplied.
Section 108(f)(5) is amended— (1) in the heading, by striking 2025 and inserting 2024, and (2) by striking January 1, 2026 and inserting January 1, 2025.
In the case of an individual, gross income does not include any amount which (but for this subsection) would be includible in gross income for such taxable year by reasons of the discharge (in whole or in part) of any loan described in subparagraph (B) after December 31, 2024, if such discharge was— (i) pursuant to subsection (a) or (d) of section 437 of the Higher Education Act of 1965 or the parallel benefit under part D of title IV of such Act (relating to the repayment of loan liability), (ii) pursuant to section 464(c)(1)(F) of such Act, or (iii) otherwise discharged on account of the death or total and permanent disability of the student.
A loan is described in this subparagraph if such loan is— (i) a student loan (as defined in paragraph (2)), or (ii) a private education loan (as defined in section 140(7) of the Consumer Credit Protection Act (15 U.S.C. 1650(7))).
Section 132 would expand qualifying 529 education-account expenses for public, private, religious, and home schools. Covered expenses would include tuition, curriculum, books, online materials, qualifying tutoring, specified tests, college dual-enrollment fees, and qualifying disability therapies. The change would apply to account distributions after enactment.
Any reference in this section to the term qualified higher education expense shall include a reference to the following expenses in connection with enrollment or attendance at, or for students enrolled at or attending, an elementary or secondary public, private, or religious school: (A) Tuition. (B) Curriculum and curricular materials. (C) Books or other instructional materials. (D) Online educational materials.
(E) Tuition for tutoring or educational classes outside of the home, including at a tutoring facility
(F) Fees for a nationally standardized norm-referenced achievement test, an advanced placement examination, or any examinations related to college or university admission. (G) Fees for dual enrollment in an institution of higher education. (H) Educational therapies for students with disabilities provided by a licensed or accredited practitioner or provider, including occupational, behavioral, physical, and speech-language therapies. Such term shall include expenses for the purposes described in subparagraphs (A) through (H) in connection with a homeschool (whether treated as a homeschool or a private school for purposes of applicable State law).
The amendment made by this section shall apply to distributions made after the date of the enactment of this Act.
For the expanded 529 rules, a tutor or instructor would have to be unrelated to the student and either hold a state teaching license, have taught at an eligible educational institution, or be an expert in the subject. Disability therapies would have to come from a licensed or accredited practitioner or provider.
but only if the tutor or instructor is not related to the student and— (i) is licensed as a teacher in any State, (ii) has taught at an eligible educational institution, or (iii) is a subject matter expert in the relevant subject.
Educational therapies for students with disabilities provided by a licensed or accredited practitioner or provider
Section 141 would repeal the personal-exemption deduction provisions while retaining and relocating the definition of a dependent to section 7706. In the dependent-definition provision, it would replace a reference to the exemption amount with $4,150, adjusted for inflation using 2017 as the reference year and rounding increases down to $50 increments. These changes would apply to tax years beginning after enactment.
141. Repeal of deduction for personal exemptions (a) In general Part V of subchapter B of chapter 1 is hereby repealed. (b) Definition of dependent retained Section 152, prior to the repeal made by subsection (a), is hereby redesignated as section 7706 and moved to the end of chapter 79.
Section 7706(d)(1)(B), as redesignated by this section, is amended by striking the exemption amount (as defined in section 151(d)) and inserting $4,150.
The $4,150 amount in paragraph (1)(B) shall be increased by an amount equal to— (A) such dollar amount, multiplied by (B) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which such taxable year begins, determined by substituting calendar year 2017 for calendar year 2016 in subparagraph (A)(ii) thereof. If any increase determined under the preceding sentence is not a multiple of $50, such increase shall be rounded to the next lowest multiple of $50.
(g) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 141 would rewrite the income-based return-filing rule. It would excuse an unmarried person whose gross income does not exceed the applicable standard deduction, and a person eligible for a joint return whose combined spousal income does not exceed the joint standard deduction, subject to additional conditions. It would also replace several personal-exemption references with dependent status or taxpayer-identification requirements.
a return shall not be required of— (A) an individual who is not married (determined by applying section 7703) and who has gross income for the taxable year which does not exceed the standard deduction applicable to such individual for such taxable year under section 63, or (B) an individual entitled to make a joint return if— (i) the gross income of such individual, when combined with the gross income of such individual’s spouse, for the taxable year does not exceed the standard deduction which would be applicable for such taxable year under section 63 if such individual and such individual’s spouse made a joint return, (ii) such individual’s spouse does not make a separate return, and (iii) neither such individual nor such individual’s spouse is an individual described in section 63(c)(4) who has income (other than earned income) in excess of the amount in effect under section 63(c)(4)(A).
Section 2(b)(1)(A)(ii) is amended by striking if the taxpayer is entitled to a deduction for the taxable year for such person under section 151 and inserting if the taxpayer included such person’s TIN on the return of tax for the taxable year.
Section 25A(g)(3) is amended by striking If a deduction under section 151 with respect to an individual is allowed to another taxpayer and inserting If an individual is a dependent of another taxpayer.
Section 141 would rewrite the exempt-amount formula in section 6334(d) concerning a tax levy. The formula would add the standard deduction to a statutory amount multiplied by the number of dependents, then divide by 52. Without a written, properly verified statement supporting the calculation, the taxpayer would be treated as married filing separately with no dependents. The surrounding levy rules are not reproduced.
Section 6334(d) is amended— (A) by amending paragraph (2) to read as follows: (2) Exempt amount (A) In general For purposes of paragraph (1), the term exempt amount means an amount equal to— (i) the sum of the amount determined under subparagraph (B) and the standard deduction, divided by (ii) 52. (B) Amount determined For purposes of subparagraph (A), the amount determined under this subparagraph is— (i) the dollar amount in effect under section 7706(d)(1)(B), multiplied by (ii) the number of the taxpayer’s dependents for the taxable year in which the levy occurs. (C) Verified statement Unless the taxpayer submits to the Secretary a written and properly verified statement specifying the facts necessary to determine the proper amount under subparagraph (A), subparagraph (A) shall be applied as if the taxpayer were a married individual filing a separate return with no dependents.
Section 142 would write a $10,000 limit on an individual's deductions for the specified state, local, and other taxes, or $5,000 for a married person filing separately. Its replacement language would also deny deductions for foreign real-property taxes. The amendment preserves text beginning 'The preceding sentence' that is not reproduced, so the full exceptions and scope cannot be determined here. The change would apply to tax years beginning after enactment.
Section 164(b)(6) is amended by striking all that precedes The preceding sentence and inserting the following:
In the case of an individual— (A) no deduction shall be allowed under this chapter for foreign real property taxes paid or accrued during the taxable year, and (B) the aggregate amount of the deduction allowed under this chapter for taxes described in paragraphs (1), (2), and (3) of subsection (a) and paragraph (5) of this subsection (and any tax described in any such paragraph taken into account under section 216(a)(1)) paid or accrued by the taxpayer during the taxable year shall not exceed $10,000 ($5,000 in the case of a married individual filing a separate return).
The amendment made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 143 would limit the residence-interest provision to 'acquisition indebtedness,' a statutory category of home debt whose full definition is not supplied. It would set a $750,000 debt ceiling, or $375,000 for married separate filers, reduced by outstanding debt in the specified older-debt categories. These are limits on qualifying debt, not dollar limits on the interest deduction. The changes would apply to tax years beginning after enactment.
Section 163(h)(3)(A) is amended by striking during the taxable year on and all that follows through residence of the taxpayer. and inserting during the taxable year on acquisition indebtedness with respect to any qualified residence of the taxpayer.
The aggregate amount treated as acquisition indebtedness for any period shall not exceed the excess (if any) of— (I) $750,000 ($375,000, in the case of a married individual filing a separate return), over (II) the sum of the aggregate outstanding pre-October 13, 1987, indebtedness (as defined in subparagraph (D)) plus the aggregate outstanding pre-December 15, 2017, indebtedness (as defined in subparagraph (C)).
The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Qualifying home debt incurred on or before December 15, 2017 would instead have a $1 million ceiling, or $500,000 for married separate filers, reduced by specified pre-October 13, 1987 debt. A dated binding-contract exception would include certain later purchases. Refinancing could retain the original borrowing date only up to the refinanced amount and within the stated time limits.
In the case of any pre-December 15, 2017, indebtedness, subparagraph (B)(ii) shall not apply and the aggregate amount of such indebtedness treated as acquisition indebtedness for any period shall not exceed the excess (if any) of— (I) $1,000,000 ($500,000, in the case of a married individual filing a separate return), over (II) the aggregate outstanding pre-October 13, 1987, indebtedness (as defined in subparagraph (D)).
The term pre-December 15, 2017, indebtedness means indebtedness (other than pre-October 13, 1987, indebtedness) incurred on or before December 15, 2017.
In the case of a taxpayer who enters into a written binding contract before December 15, 2017, to close on the purchase of a principal residence before January 1, 2018, and who purchases such residence before April 1, 2018, the term pre-December 15, 2017, indebtedness shall include indebtedness secured by such residence.
such refinanced indebtedness shall be treated for purposes of this subparagraph as incurred on the date that the original indebtedness was incurred to the extent the amount of the indebtedness resulting from such refinancing does not exceed the amount of the refinanced indebtedness.
Subclause (I) shall not apply to any indebtedness after the expiration of the term of the original indebtedness or, if the principal of such original indebtedness is not amortized over its term, the expiration of the term of the 1st refinancing of such indebtedness (or if earlier, the date which is 30 years after the date of such 1st refinancing).
Section 144 would remove the 2018–2025 time restriction from the personal-casualty-loss provision and retitle it to refer to losses attributable to federally declared disasters. This would apply to losses sustained in tax years beginning after enactment. The underlying loss rules and exceptions are not fully reproduced.
Section 165(h)(5)(A) is amended by striking in a taxable year beginning after December 31, 2017, and before January 1, 2026,.
Section 165(h)(5) is amended by striking for taxable years 2018 through 2025 in the heading thereof and inserting to losses attributable to Federally declared disasters.
The amendments made by this section shall apply to losses sustained in taxable years beginning after the date of the enactment of this Act.
Section 145 would deny individuals the statutory category called miscellaneous itemized deductions, without stating an end date. For estates and trusts, it would relocate a rule allowing specified administration costs and listed deductions when calculating adjusted gross income. The changes would apply to tax years beginning after enactment.
In the case of an individual, miscellaneous itemized deductions shall not be allowed.
the adjusted gross income of an estate or trust shall be computed in the same manner as in the case of an individual, except that— (1) the deductions for costs which are paid or incurred in connection with the administration of the estate or trust and which would not have been incurred if the property were not held in such trust or estate, and (2) the deductions allowable under sections 642(b), 651, and 661, shall be treated as allowable in arriving at adjusted gross income.
The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 146 would repeal tax-code section 68, identified here as the overall limitation on itemized deductions. It would also insert filing-status amounts into a cross-referenced tax-deduction rule: $300,000 for joint returns or surviving spouses, $275,000 for heads of household, $250,000 for other unmarried filers, and half the joint amount for married separate filers, with inflation adjustments. The unreproduced surrounding rule limits what can be concluded about those amounts.
146. Repeal of overall limitation on itemized deductions (a) In general Part 1 of subchapter B of chapter 1 is amended by striking section 68
the term applicable amount means— (I) $300,000 in the case of a joint return or a surviving spouse, (II) $275,000 in the case of a head of household, (III) $250,000 in the case of an individual who is not married and who is not a surviving spouse or head of household, and (IV) ½ the amount applicable under subclause (I) in the case of a married individual filing a separate return.
each of the dollar amounts in this clause shall be increased by an amount equal to such dollar amount, multiplied by the cost-of-living adjustment determined under section 1(f)(3)
Section 147 would terminate the income exclusion for qualified bicycle-commuting reimbursements by deleting the relevant provision and related text. It would also remove a 2018–2025 date restriction from section 274(l)(2), whose underlying rule is not reproduced. These amendments would apply to tax years beginning after enactment.
147. Termination of exclusion for qualified bicycle commuting reimbursement (a) In general Section 132(f)(1) is amended by striking subparagraph (D).
Section 274(l)(2) is amended by striking after December 31, 2017, and before January 1, 2026.
The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 148 would restrict the moving-expense reimbursement exclusion to active-duty U.S. Armed Forces members moving under military orders because of a permanent change of station. The restriction would apply to tax years beginning after enactment.
Section 132(g) is amended— (1) by striking by an individual in paragraph (1) and inserting by a qualified military individual
the term qualified military individual means a member of the Armed Forces of the United States on active duty who moves pursuant to a military order and incident to a permanent change of station.
The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 149 would likewise limit the moving-expense deduction to qualifying active-duty military moves. It would exclude covered moving and storage services or reimbursements for the member, spouse, or dependents from income, with reimbursements limited to actual expenses, and remove specified Defense or Transportation Department reporting requirements. Special rules would cover spouses and dependents moving to or from a different location. The changes would apply to tax years beginning after enactment.
There shall be allowed as a deduction moving expenses paid or incurred during the taxable year by a member of the Armed Forces of the United States on active duty who moves pursuant to a military order and incident to a permanent change of station.
Any moving and storage expenses which are furnished in-kind (or for which reimbursement or an allowance is provided, but only to the extent of the expenses paid or incurred)— (1) to a member described in subsection (a), or to such member’s spouse or dependents, shall not be includible in gross income, and no reporting with respect to such expenses shall be required by the Secretary of Defense or the Secretary of Transportation, as the case may be
to the spouse and dependents of a member described in subsection (a) with regard to moving to a location other than the one to which such member moves (or from a location other than the one from which such member moves), this section shall apply with respect to the moving expenses of such spouse and dependents as if such spouse were a member described in subsection (a).
The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 150 would remove the 2018–2025 date restriction from a wagering-loss provision, beginning with tax years starting after enactment. The supplied amendment does not reproduce the underlying gambling-loss calculation, so it does not establish the amount deductible.
150. Limitation on wagering losses (a) In general Section 165(d) is amended by striking in the case of taxable years beginning after December 31, 2017, and before January 1, 2026,. (b) Effective date The amendment made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
Section 151 would replace $5 million with $10 million in the estate-and-gift-tax exemption provision and delete subparagraph (C). It would apply to estates of people dying after enactment and to gifts made after enactment. The surrounding exemption and adjustment rules are not reproduced, so $10 million should not be read as a verified final exemption for a particular year.
151. Increase in estate and gift tax exemption (a) In general Section 2010(c)(3) is amended in subparagraph (A), by striking $5,000,000 and inserting $10,000,000. (b) Conforming amendment Section 2010(c)(3) is amended by striking subparagraph (C). (c) Effective date The amendments made by this section shall apply to estates of decedents dying and gifts made after the date of the enactment of this Act.
Section 201 would increase two alternative-minimum-tax exemption amounts from $78,750 to $109,400 and from $50,600 to $70,300. It would replace one exemption phaseout amount with $1 million, set another at half that amount, and specify $75,000 for a third category. The underlying category definitions are not supplied.
II Increased exemption for Alternative Minimum Tax made permanent
Section 55(d)(1) is amended— (1) by striking $78,750 in subparagraph (A) and inserting $109,400, and (2) by striking $50,600 in subparagraph (B) and inserting $70,300.
(b) Phase-Out of exemption amount Section 55(d)(2) is amended— (1) by striking $150,000 in subparagraph (A) and inserting $1,000,000, and (2) by striking subparagraphs (B) and (C) and by inserting the following new subparagraphs: (B) 50 percent of the dollar amount applicable under subparagraph (A) in the case of a taxpayer described in paragraph (1)(B) or (1)(C), and (C) $75,000 in the case of a taxpayer described in paragraph (1)(D).
Section 201 would adjust specified alternative-minimum-tax amounts for inflation using either 2011 or 2017 as the reference year. It would also delete section 59(j), under a heading concerning coordination with rules for children's unearned income, and section 55(d)(4). These amendments would apply to tax years beginning after enactment; the deleted rules are not reproduced.
determined by substituting— (i) in the case of a dollar amount contained in paragraph (1)(D) or (2)(C) or in subsection (b)(1)(A), calendar year 2011 for calendar year 2016 in subparagraph (A)(ii) thereof, and (ii) in the case of a dollar amount contained in paragraph (1)(A), (1)(B), or (2)(A), calendar year 2017 for calendar year 2016 in subparagraph (A)(ii) thereof.
(d) Repeal of coordination with rules relating to the taxation of unearned children Section 59 is amended by striking subsection (j). (e) Conforming amendment Section 55(d) is amended by striking paragraph (4). (f) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.
The supplied official-actions snapshot, updated September 19, 2026, records introduction in the House and referral to the House Committee on Ways and Means on January 3, 2025. This dated snapshot does not establish the bill's subsequent disposition.
Source snapshot updated 2026-09-19T23:07:26Z. 2025-01-03: Referred to the House Committee on Ways and Means. 2025-01-03: Introduced in House
A closer look
Reviewed version: Introduced in House · 2025-01-03. These findings describe provisions and who may benefit; they are not judgments of waste, corruption, or motive.
This review covers the supplied bill text. “None identified” does not rule out provisions in later versions or accompanying reports and disclosures.
Provisions outside the bill’s main subject, or policy changes attached to appropriations.
None identified in the reviewed text
No provision unrelated to the bill's tax-policy subject, or policy change attached to appropriations, was identified in the complete supplied introduced text. This conclusion is limited to that version and does not establish the absence of riders in other versions or accompanying materials.
Spending directed to particular recipients or places outside ordinary competitive or formula-based allocation.
None identified in the reviewed text
No congressionally directed spending for a particular recipient or place was identified in the complete supplied introduced text. This text-only conclusion does not establish formal earmark status or absence in other versions or accompanying materials.
Narrow exceptions, exemptions, or preferential treatment that warrant a closer look.
Findings to examine
The findings identify materially narrow tax exceptions and special treatment within the bill's main tax policy. Classification does not establish their merits, motivation, or origins.
Section 126 singles out service in Egypt's Sinai Peninsula for inclusion in section 112's geographic tax treatment, conditional on at least one U.S. service member being entitled to hostile-fire or imminent-danger special pay for service there. This is a geographically targeted rule for qualifying service in that area; the underlying section 112 rules are not fully reproduced, so the complete tax benefit and eligibility cannot be established here.
Section 112(c)(2) is amended— (1) by striking means any area and inserting means— (A) any area , and (2) by striking the period at the end and inserting , and (B) the Sinai Peninsula of Egypt.
such service is performed during any period with respect to which one or more members of the Armed Forces of the United States are entitled to special pay under section 310 of title 37, United States Code (relating to special pay; duty subject to hostile fire or imminent danger), for service performed in such area.
Sections 148 and 149 reserve moving-expense tax treatment for active-duty military members moving under orders for a permanent change of station. Section 149 extends specified income exclusions to their spouses and dependents. These are occupational exceptions to the bill's restrictions on moving-expense benefits.
Section 132(g) is amended— (1) by striking by an individual in paragraph (1) and inserting by a qualified military individual
the term qualified military individual means a member of the Armed Forces of the United States on active duty who moves pursuant to a military order and incident to a permanent change of station.
There shall be allowed as a deduction moving expenses paid or incurred during the taxable year by a member of the Armed Forces of the United States on active duty who moves pursuant to a military order and incident to a permanent change of station.
Any moving and storage expenses which are furnished in-kind (or for which reimbursement or an allowance is provided, but only to the extent of the expenses paid or incurred)— (1) to a member described in subsection (a), or to such member’s spouse or dependents, shall not be includible in gross income
Section 143 provides a narrow binding-contract exception for principal-home purchasers who contracted before December 15, 2017 to close before January 1, 2018 and purchased before April 1, 2018. Their secured debt could receive the older-debt treatment, whose ceiling is $1 million rather than the general $750,000, with separate-return reductions and adjustments for older outstanding debt.
In the case of a taxpayer who enters into a written binding contract before December 15, 2017, to close on the purchase of a principal residence before January 1, 2018, and who purchases such residence before April 1, 2018, the term pre-December 15, 2017, indebtedness shall include indebtedness secured by such residence.
The aggregate amount treated as acquisition indebtedness for any period shall not exceed the excess (if any) of— (I) $750,000 ($375,000, in the case of a married individual filing a separate return), over (II) the sum of the aggregate outstanding pre-October 13, 1987, indebtedness (as defined in subparagraph (D)) plus the aggregate outstanding pre-December 15, 2017, indebtedness (as defined in subparagraph (C)).
In the case of any pre-December 15, 2017, indebtedness, subparagraph (B)(ii) shall not apply and the aggregate amount of such indebtedness treated as acquisition indebtedness for any period shall not exceed the excess (if any) of— (I) $1,000,000 ($500,000, in the case of a married individual filing a separate return), over (II) the aggregate outstanding pre-October 13, 1987, indebtedness (as defined in subparagraph (D)).
Section 131 provides a targeted gross-income exclusion for individuals whose qualifying student or private education loans are discharged after December 31, 2024 under specified federal provisions or because of the student's death or total and permanent disability. The benefit excludes discharge amounts that otherwise would enter the individual's gross income. Alongside this condition-specific exception, the bill moves the cutoff in the existing section 108(f)(5) discharge rule from January 1, 2026 to January 1, 2025. The earlier rule and referenced loan and federal discharge definitions are not reproduced, so the complete beneficiary population and change from prior treatment cannot be established from this source.
Section 108(f)(5) is amended— (1) in the heading, by striking 2025 and inserting 2024, and (2) by striking January 1, 2026 and inserting January 1, 2025.
In the case of an individual, gross income does not include any amount which (but for this subsection) would be includible in gross income for such taxable year by reasons of the discharge (in whole or in part) of any loan described in subparagraph (B) after December 31, 2024, if such discharge was— (i) pursuant to subsection (a) or (d) of section 437 of the Higher Education Act of 1965 or the parallel benefit under part D of title IV of such Act (relating to the repayment of loan liability), (ii) pursuant to section 464(c)(1)(F) of such Act, or (iii) otherwise discharged on account of the death or total and permanent disability of the student.
(B) Loans described A loan is described in this subparagraph if such loan is— (i) a student loan (as defined in paragraph (2)), or (ii) a private education loan (as defined in section 140(7) of the Consumer Credit Protection Act (15 U.S.C. 1650(7))).
(c) Effective date The amendments made by this section shall apply to discharges of indebtedness after December 31, 2024.
Full text preserved for this analysis. Legislative record snapshot: Sep 19, 2026. How PlainBill uses AI