Following are highlights of the major changes to the tax-related portions of the bill:
- Provisions to tighten the carried interest rules were removed from the bill.
- The bill includes a 1% excise tax on certain corporate stock buybacks.
- The bill extends through the end of 2028 the IRC Section 461(l) limit on excess business losses for noncorporate taxpayers that was set to expire at the end of 2025 under the Tax Cuts and Jobs Act of 2017.
- The scope of the 15% corporate alternative minimum tax was narrowed, including changes that could exclude some investment fund portfolio companies from the tax.
The Senate-passed bill retains, with some modification, the significant incentives for clean energy included in the version introduced by Senate Democrats. It also retains increased IRS funding.
Although a late attempt was made to extend the state and local tax (SALT) cap to fill the revenue gap created by changes needed to pass the Senate, extension of the SALT cap did not make it into the final bill.