BUSINESSES & CORPORATIONS -
Foreign Income Tax Regime Reforms
- The foreign-derived intangible income (FDII) framework was renamed FDDEI and revised, with revised deduction calculations and expanded definitions.
- GILTI reform: "Global Intangible Low-Taxed Income" is now Net CFC Tested Income with updated rates and rules.
Qualified Business Income (QBI) Deduction
- Section 199A deduction (20% for pass-throughs) is extended (permanent under current law), providing ongoing tax relief for LLCs, S-corps, partnerships.
Immediate Expensing of R&D Costs
- New provisions allow full expensing of domestic research and experimental expenditures for eligible businesses instead of long amortization.
Estate & Gift Tax Changes
- Estate and gift tax exemptions are permanently increased (about $15M individual / $30M married), with future inflation adjustments.
Enhanced Business Incentives
- Expanded opportunity zones program, bonus depreciation, and full expensing of qualified production property.
Compliance & Reporting Updates Still Phased In
- For tax year 2025 filings, key payroll forms and withholding tables remain unchanged while IRS phases in new reporting requirements for tips and overtime.