Tax insight

H.R. 1, the “One Big Beautiful Bill Act,” signed by President Trump: Key provisions for high net worth individuals, family offices, and family businesses

Insight
9 minute read
July 22, 2025

What happened?

On July 4, President Donald J. Trump signed into law H.R. 1, the “One Big Beautiful Bill Act” (the Act). The Act modifies and makes permanent many of the 2017 TCJA business, international, and individual tax provisions that were set to change at the end of this year. H.R. 1 contains tax law changes with various effective dates, including the Act’s July 4 date of enactment for some provisions.

Why is it relevant?

The Act includes provisions that could significantly impact high net worth individuals, family offices, and family businesses. Despite the disagreement between the House and the Senate as it relates to the $10,000 SALT cap, the final bill increases the cap on a temporary basis to $40,000, subject to an overall phaseout for certain taxpayers. Other impactful provisions include making permanent the excess business loss limitation for noncorporate taxpayers and the 20% pass-through business deduction under Section 199A, as well as the new expansion of the qualified small business stock exclusion and the increase to the lifetime gift, estate, and GST exemption.

The Act also restores 100% bonus depreciation under Section 168(k), expensing for US-based research under Section 174, and the EBITDA-based business interest expense limitation under Section 163(j).

The Act does not include provisions affecting the pass-through entity tax (PTET) deduction, carried interest, credit unions’ tax-exempt status, cryptocurrency, or rate increases on high income taxpayers.

Action to consider 

Now that the Act has been signed into law, high net worth individuals, families, and their advisors should evaluate the potential effect of the tax law changes and consider any steps that might be beneficial to take before or after the legislation’s various effective dates.