Tax insight

H.R. 1 heads to the Senate: Key proposals for family offices and high net worth individuals

  • Insight
  • 10 minute read
  • June 05, 2025

What happened? 

The House on May 22 voted to pass H.R. 1, the “One Big Beautiful Bill Act” (the Bill), which includes proposed tax law changes with an estimated net cost of $3.8 trillion over 10 years and also includes a provision to increase the federal statutory debt limit by $4 trillion.   

The Senate is expected to consider changes to the House-passed bill. Both the House and Senate would have to agree on a final identical version of H.R. 1 before the legislation can be sent to the White House for signing by President Trump. While Congressional Republican leaders hope to send a final bill to President Trump before Congress begins a July 4 recess, resolving differences between the House-passed bill and any changes approved by the Senate could extend work on the legislation until later in July.   

Why is it relevant?

The Bill includes several proposals that could significantly impact the high net worth individuals and their family offices including the disallowance of state pass-through entity taxes at the partnership level, increasing the state and local tax cap for certain individuals, making permanent the excess loss limitations for noncorporate taxpayers, and increasing US tax for inbound investors resident in “foreign discriminatory” countries on certain of their US sourced income.  

Notably, the House passed bill does not include proposals affecting carried interest, a new general limitation on deductions for state and local property taxes for businesses, credit unions’ tax-exempt status, the exclusion for gain related to qualified small business stock, crypto-related tax proposals, or rate increases on high income taxpayers.

Action to consider 

Families and their advisors should evaluate the potential effect of proposed tax law changes and consider any steps that might be taken before or after the legislation’s various proposed effective dates that could be beneficial. Assessing the potential effects of proposed tax law changes also will need to take into account any changes made by the Senate and in any final bill approved by both chambers.   

For an in-depth look at all the key provisions in the Bill see our prior Insight – Overview of House-passed H.R. 1, the “One Big Beautiful Bill Act.  

H.R. 1 heads to the Senate: Key proposals for family offices and high net worth individuals

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Ed Geils

Ed Geils

Global and US Tax Knowledge Management Leader, PwC US

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