House Ways & Means Committee Releases Partial Text Tax Bill

On May 9, 2025, the House Ways & Means Committee released a partial text (only 28 pages of a bill that is expected to exceed 200 pages) of the tax provisions that are proposed to be included in the final text of the much-anticipated reconciliation bill. This initial Chairman’s Mark contains only the provisions that would extend some of the provisions in the 2017 Tax Cuts and Jobs Act (TCJA).

The partial bill would make permanent many of the TCJA’s expiring provisions and modify others. For example, it would increase the standard deduction by $1,000 for individuals and $2,000 for married couples filing jointly, and it would increase the qualified business income (QBI or §199A) deduction for pass-through entities from 20% to 22%. It also would increase the base amount of the lifetime estate and gift tax credit from $5 million to $15 million.

In the international tax context, the proposal would lower the preferential rates on GILTI and FDII by increasing the deduction for corporations from 37.5% to 50% of GILTI (including the corresponding §78 gross-up amount) and from 21.875% to 37.5% of FDII.

The partial release does not address the top 3 business tax provisions that are expected to be included in the final bill (R&E expensing under §174, 100% bonus depreciation, and a relaxation of the §163(j) interest deduction limitation), as well as an increase in the $10,000 state and local tax deduction limitation.

The bill also does not address the fate of Biden’s clean-energy tax credits and some new tax provisions that are expected to be addressed in the final bill, including a new limitation on businesses’ ability to deduct state and local taxes, tax-free tips and overtime pay, and an increased tax rate on individuals making over $1 million or $2.5 million.

This current release is only a partial and initial draft, and there is much more to come. Another Chairman’s Mark is expected this week along with the Committee markups. Then, the House will release its final version of the bill before sending it to the Senate, where changes are certain to be made.

It is still very early, and while the final bill is expected to be released and possibly signed by the President by July 4^th, there will be many inclusions and deletions until a final draft emerges.