
Senate Bill Proposes Permanent LIHTC Expansion
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Diverging Reports Breakdown
Tax provisions of Senate Finance’s version of the budget bill
The Senate Finance Committee released its version of proposed tax provisions. The Senate is considering its own version of the bill, which has to meet certain criteria to be exempt from the Senate’s filibuster rules. Many tax provisions in the Senate bill are similar to those in the bill that passed the House in May. But the Senate version would retain the $10,000 state and local tax deduction limit, although the amount of the cap is still being negotiated. It would also repeal various clean-energy credits and incentives that were enacted as part of the Inflation Reduction Act of 2022, P.L. 117-169. The bill would provide a temporary $6,000 deduction for individual taxpayers who are age 65 or older, but the House bill provided a $4,000 “senior bonus” deduction for those individuals. And it would permanently set the deduction for personal exemptions at zero, as the House passed it. The House bill originally would have increased that to $30,000; the House increased the cap to $40,000 for married taxpayers filing separately.
Many tax provisions in the Senate Finance Committee’s version of the bill are similar to tax provisions in the bill that passed the House. For example, like the House bill, the Senate bill would repeal various clean-energy credits and incentives that were enacted as part of the Inflation Reduction Act of 2022, P.L. 117-169.
Although the text of the proposed bill runs to 549 pages, the text is apparently not complete. One section of the bill is marked “reserved” — a section labeled “tax treatment of certain international entrepreneurs.” And while the Senate version of the bill retains the House bill’s provision creating Trump savings accounts, the Finance Committee says that “further refinements to the text included in the House-passed H.R. 1 with respect to the Trump accounts program continue to be developed and finalized in coordination with the Trump Administration.”
And although the bill retains the $10,000 state and local tax deduction limit (SALT cap), the Senate Finance Committee’s explanation of the bill says that “the amount of the individual SALT cap is the subject of continuing negotiations.”
Here’s a look at the key tax provisions in the Senate’s proposed legislative language that differ from the bill that passed the House.
Provisions for individuals
Tax rates: Like the House bill, the Senate bill would make permanent the tax rates enacted in 2017 in the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. The bill would add an additional year of inflation adjustment to the 10%, 12%, and 22% individual tax brackets.
Standard deduction: Like the House bill, the Senate bill would make the TCJA’s increased standard deduction amounts permanent. For tax years beginning after 2025, the standard deduction would increase to $16,000 for single filers, $24,000 for heads of household, and $32,000 for married individuals filing jointly. The standard deduction would be adjusted for inflation after that.
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Personal exemptions and senior deduction: Like the House bill, the Senate bill would permanently set the deduction for personal exemptions at zero. The Senate bill would provide a temporary $6,000 deduction for individual taxpayers who are age 65 or older. The House bill provided a temporary $4,000 “senior bonus” deduction for those individuals. The Senate’s senior deduction would begin to phase out when a taxpayer’s modified adjusted gross income (MAGI) exceeds $75,000 ($150,000 in the case of a joint return). It would be in effect for the years 2025 through 2028.
SALT cap: The current law caps an individual’s state and local tax deduction at $10,000. The House bill originally would have increased that to $30,000; however, the manager’s amendment approved by the House increased the cap to $40,000 per household ($20,000 for married taxpayers filing separately) starting in 2025. The Senate version of the bill would retain the current $10,000 cap, but, as noted above, this provision is still being negotiated. The Senate bill would also implement changes to prevent taxpayers from avoiding the SALT cap.
The bill would provide a list of taxes subject to the SALT cap (“specified taxes” and passthrough entity taxes (PTETs)) and a list of taxes not subject to a SALT cap (“excepted taxes”). It would provide that certain payments that substitute for specified taxes are also subject to the SALT cap, and it would require partnerships and S corporations to treat specified taxes and PTETs as separately stated items. The bill would impose an addition to tax in certain cases where a partnership makes a state or local tax payment, one or more partners receive a state or local tax benefit, and the allocation of the tax payment differs from the allocation of the tax benefit. It would prevent the capitalization of specified taxes and would grant Treasury authority to issue regulations to prevent avoidance of the SALT cap.
The House bill also included a provision that would have barred owners of specified trades or businesses (SSTBs) (borrowing the definition from the qualified business income (QBI) deduction under Sec. 199A) from claiming any deduction for PTETs. The Senate version does not include the same provision. Rather, it limits all passthrough entity owners’ PTET SALT deduction to the unused portion of their SALT deduction plus the greater of $40,000 of their allocation of the PTET or 50% of their allocation of the PTET.
In reaction to the House bill’s version of this measure, AICPA President and CEO Mark Koziel, CPA, CGMA, called the PTET changes “unfair” to affected passthrough businesses, including accounting firms.
Child tax credit: The Senate bill would increase the amount of the nonrefundable child tax credit to $2,200 per child beginning in 2025 (a different amount from the House bill) and would index the credit amount for inflation. The bill would also make permanent the $1,400 refundable child tax credit, adjusted for inflation. It would also make permanent the increased income phaseout threshold amounts of $200,000 ($400,000 in the case of a joint return), as well as the $500 nonrefundable credit for each dependent of the taxpayer other than a qualifying child.
QBI deduction: TheSenate bill would make the Sec. 199A deduction for QBI permanent. It would expand the Sec. 199A deduction limit phase-in range for SSTBs and other entities subject to the wage and investment limitation by increasing the $50,000 amount for non-joint returns to $75,000 and the $100,000 amount for joint returns to $150,000.
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The bill would also introduce an inflation-adjusted minimum deduction of $400 for taxpayers who have at least $1,000 of QBI from one or more active trades or businesses in which they materially participate.
The House bill would raise the QBI deduction rate from 20% to 23%. The Senate would keep the rate at 20%.
Estate and gift tax exemption amounts: The Senate bill would permanently increase the estate tax exemption and lifetime gift tax exemption amounts to $15 million for single filers ($30 million for married filing jointly) in 2026 and index the exemption amount for inflation after that.
Alternative minimum tax exemption: The Senate bill would permanently extend the TCJA’s increased individual alternative minimum tax exemption amounts and revert the exemption phaseout thresholds to their 2018 levels of $500,000 ($1 million in the case of a joint return), indexed for inflation.
Mortgage interest deduction: The Senate bill would permanently extend the TCJA’s provision limiting the Sec. 163 qualified residence interest deduction to the first $750,000 in home mortgage acquisition debt. It would also make permanent the exclusion of interest on home-equity indebtedness from the definition of qualified residence interest. The Senate bill would also treat certain mortgage insurance premiums on acquisition indebtedness as qualified residence interest.
Casualty loss deductions: Under the Senate bill, the TCJA’s provision limiting the itemized deduction for personal casualty losses to losses resulting from federally declared disasters would become permanent, but the bill would expand the provision to include certain state-declared disasters.
Miscellaneous itemized deductions: The Senate bill would make permanent the TCJA’s suspension of the Sec. 67(g) deduction for miscellaneous itemized deductions but would remove unreimbursed employee expenses for eligible educators from the list of miscellaneous itemized deductions.
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Itemized deductions limitation: The bill would permanently remove the Sec. 68 overall limitation on itemized deductions (known as the Pease limitation) and replace it with a new overall limitation on the tax benefit of itemized deductions. For individual taxpayers in the highest tax bracket, the provision would cap the value of each dollar of otherwise allowable itemized deductions at 35 cents.
Wagering losses: The Senate bill would amend Sec. 165(d) to clarify that the term “losses from wagering transactions” includes any deduction otherwise allowable under Chapter 1 of the Code incurred in carrying on any wagering transactions. The bill would limit the term “losses from wagering transactions” to 90% of the amount of those losses, and losses would be deductible only to the extent of the taxpayer’s gains from wagering transactions during the tax year.
No tax on tips: The Senate bill would provide a deduction of up to $25,000 for qualified tips received by an individual in an occupation that customarily and regularly receives tips. The deduction would be allowed for both employees receiving a Form W-2, Wage and Tax Statement, and independent contractors who receive Form 1099-K, Payment Card and Third Party Network Transactions, or Form 1099-NEC, Nonemployee Compensation, or who report tips on Form 4317, Social Security and Medicare Tax on Unreported Tip Income. The deduction would be an above-the-line deduction and, therefore, available for taxpayers who claim the standard deduction or itemize deductions. The deduction would begin to phase out when the taxpayer’s MAGI exceeds $150,000 ($300,000 in the case of a joint return). This temporary deduction would be available for tax years 2025 through 2028. A transition rule would allow employers required to furnish statements enumerating an individual’s tips for tax year 2025 to use “any reasonable method” to estimate designated tip amounts.
No tax on overtime: The Senate bill would provide an above-the-line deduction of up to $12,500 ($25,000 in the case of a joint return) for qualified overtime compensation received by an individual during a given tax year. The deduction would begin to phase out when the taxpayer’s MAGI exceeds $150,000 ($300,000 in the case of a joint return). The bill defines qualified overtime compensation as overtime compensation paid to an individual required under Section 7 of the Fair Labor Standards Act of 1938that is in excess of the regular rate (as used in that section) at which the individual is employed. Overtime deductions would only be allowed for qualified overtime compensation if the total amount of qualified overtime compensation is reported separately on Form W-2. This temporary deduction would be available for tax years 2025 through 2028.
Child and dependent care credit: The Senate bill would permanently increase the amount of the child and dependent care tax credit from 35% to 50% of qualifying expenses. The credit rate would phase down for taxpayers with adjusted gross income over $15,000.
Sec. 529 plans: The Senate bill would allow tax-exempt distributions from Sec. 529 savings plans to be used for additional educational expenses in connection with enrollment or attendance at an elementary or secondary school. The bill would also allow tax-exempt distributions from 529 savings plans to be used for additional qualified higher education expenses, including “qualified postsecondary credentialing expenses.”
Charitable contribution deduction: The Senate bill would create a charitable contribution deduction for taxpayers who do not elect to itemize, allowing nonitemizers to claim a deduction of up to $1,000 for single filers or $2,000 for married taxpayers filing jointly for certain charitable contributions. For itemizers, the bill would impose a 0.5% floor on the charitable contribution deduction: The amount of an individual’s charitable contributions for a tax year is reduced by 0.5% of the taxpayer’s contribution base for the tax year. For corporations, the floor would be 1% of the corporation’s taxable income (up to the current 10% limit).
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Business provisions
Bonus depreciation: The Senate bill would permanently extend the Sec. 168 additional first-year (bonus) depreciation deduction. The allowance would be increased to 100% for property acquired and placed in service on or after Jan. 19, 2025, as well as for specified plants planted or grafted on or after Jan. 19, 2025. The House bill would have implemented 100% bonus depreciation from Jan. 19, 2025, through the end of 2029.
Sec. 179 expensing: The Senate bill would increase the maximum amount a taxpayer may expense under Sec. 179 to $2.5 million, reduced by the amount by which the cost of qualifying property exceeds $4 million.
Research-and-development expenses: The Senate bill would allow taxpayers to immediately deduct domestic research or experimental expenditures paid or incurred in tax years beginning after Dec. 31, 2024. However, research or experimental expenditures attributable to research that is conducted outside the United States would continue to be required to be capitalized and amortized over 15 years under Sec. 174.
Small business taxpayers with average annual gross receipts of $31 million or less would generally be permitted to apply this change retroactively to tax years beginning after Dec. 31, 2021. And all taxpayers that made domestic research or experimental expenditures after Dec. 31, 2021, and before Jan. 1, 2025, would be permitted to elect to accelerate the remaining deductions for those expenditures over a one- or two-year period.
Limitation on business interest: The Senate bill would reinstate the EBITDA limitation under Sec. 163(j) for tax years beginning after Dec. 31, 2024. Therefore, for purposes of the Sec. 163(j) interest deduction limitation for these years, adjusted taxable income would be computed without regard to the deduction for depreciation, amortization, or depletion. The bill would also modify the definition of “motor vehicle” to allow interest on floor plan financing for certain trailers and campers to be deductible.
Special depreciation allowance for qualified production property: The Senate bill would allow an additional first-year depreciation deduction equal to 100% of the adjusted basis of “qualified production property.” Qualified production property is generally nonresidential real property used in manufacturing.
Advanced manufacturing investment credit: Under the Senate bill, the advanced manufacturing investment credit rate would increase from 25% to 30%, effective for property placed in service after Dec. 31, 2025.
Employer-provided child care credit: The Senate bill would increase the Sec. 45F employer-provided child care credit from $150,000 to $500,000 and the percentage of qualified child care expenses from 25% to 40%. The rate would be 50% for qualifying small businesses (meeting the gross-receipts test under Sec. 448(c) using a five-year, rather than a three-year, average of gross receipts).
Opportunity zones: The Senate bill would make opportunity zones permanent but with several changes, including narrowing the definition of “low-income community.” The changes would take effect Jan. 1, 2027.
International provisions
Foreign tax credit: The Senate bill would limit the deductions of a U.S. shareholder allocable to income in the global intangible low-tax income (GILTI) category when determining its foreign tax credit limitation. It would also modify the determination of deemed paid credit for taxes properly attributable to tested income and change the rules for sourcing certain income from the sale of inventory produced in the United States.
GILTI and FDII: The Senate bill would decrease the Sec. 250 deduction percentage for tax years beginning after Dec. 31, 2025, to 33.34% for foreign-derived intangible income (FDII) and 40% for GILTI, resulting in an effective tax rate of 14% for both FDII and GILTI. The bill also proposes changing the definition of deduction-eligible income for purposes of determining FDII. The bill would also eliminate the use of a corporation’s deemed tangible income return for determining FDII and the use of net deemed tangible income return in determining GILTI. These changes would then result in the elimination of the terms FDII and GILTI, which would be renamed “foreign-derived deduction eligible income” and “net CFC tested income,” respectively.
BEAT: The Senate bill would make various changes to the current base-erosion and anti-abuse tax (BEAT). These changes would include adjustments to the calculation of the base-erosion minimum tax amount, exempting certain payments that are subject to sufficient foreign income tax from treatment as base-erosion payments, and reducing the base-erosion percentage threshold from 3% to 2%.
Business interest limitation: The Senate bill would provide that the Sec. 163(j) business interest limitation would be calculated prior to the application of any interest capitalization provision. The bill would also exclude Subpart F and GILTI inclusions and the associated Sec. 78 gross-up amounts, as well as amounts determined under Sec. 956, from a taxpayer’s adjusted taxable income for purposes of Sec. 163(j).
Unfair foreign taxes: The Senate bill would impose increased rates of tax (up to 15%) on certain affected taxpayers connected to countries that are deemed to impose unfair foreign taxes. The affected taxpayers would include foreign governments, resident individuals, resident corporations, resident foreign private foundations, and entities owned by such persons. The bill would also subject certain domestic entities owned by a tax resident of an offending foreign country to certain modifications to the BEAT that would expand the scope of entities subject to the BEAT.
Administrative changes
Employee retention credit enforcement: The Senate bill would require employee retention credit (ERC) promoters to comply with due diligence requirements with respect to a taxpayer’s eligibility for (or the amount of) an ERC. The bill would apply a $1,000 penalty for each failure to comply. It would also extend the penalty for excessive refund claims to employment tax refund claims. It would also prevent the IRS from issuing any additional unpaid claims under Sec. 3134, unless a claim for a credit or refund was filed on or before Jan. 31, 2024.
Earned income tax credit: The Senate bill would create a new earned income tax credit (EITC) certification program for tax years after 2027 (with transition rules beginning in 2024) to allow the IRS to detect and manage duplicative EITC claims.
— Alistair M. Nevius, J.D., is a freelance writer in North Carolina. To comment on this article or to suggest an idea for another article, contact Neil Amato at Neil.Amato@aicpa-cima.com.
Updates on individual tax and business tax are among the many topics on the agenda at the AICPA & CIMA National Tax Conference, Nov. 17–18 in Washington, D.C., and online.
Senate Version of Tax Bill Retains Key Housing, Business Provisions
The Senate Finance Committee on Monday evening unveiled its portion of the One Big Beautiful Bill Act. The bill includes some changes to the House-passed version, which means if it passes the Senate it will go to a vote again in the House before making its way to the president’s desk to be signed into law.Like the House bill, the Senate version includes several provisions that NAHB believes are very positive for small businesses, real estate and our members.NAHB secured several key victories in the Senate tax bill:Individual Provisions: The Tax Cuts and Jobs Act would be made permanent, including the tax rate structure and increased exemptions for the Alternative Minimum Tax. The Low-Income Housing Tax Credit would be expanded. The 1099 reporting threshold would be increased permanently to $2,000 and indexed for inflation starting for 2025. The House bill would increase the controversial limit on state and local tax (SALT) deductions for individuals from the current $10,000 to $40,000.
Like the House bill, the Senate version includes several provisions that NAHB believes are very positive for small businesses, real estate and our members.
NAHB secured several key victories in the Senate tax bill:
Individual Provisions
The Tax Cuts and Jobs Act would be made permanent, including the tax rate structure and increased exemptions for the Alternative Minimum Tax.
would be made permanent, including the tax rate structure and increased exemptions for the Alternative Minimum Tax. The estate tax exemption would increase to $15 million, made permanent and be indexed for inflation.
would increase to $15 million, made permanent and be indexed for inflation. Current mortgage interest deduction rules would be made permanent and mortgage insurance premiums would now be allowed to be deducted.
rules would be made permanent and mortgage insurance premiums would now be allowed to be deducted. The Pease limitation on itemized deductions would be permanently repealed. In its place is a new limitation that reduces the value of itemized deductions for taxpayers in the top bracket from 37 cents to 35 cents, but excludes 199A deductions for this limitation.
Business Provisions
The Section 199A Qualified Business Income Deduction , which helps provide tax parity for pass-through entities, would be made permanent at 20%.
, which helps provide tax parity for pass-through entities, would be made permanent at 20%. The Low-Income Housing Tax Credit would be expanded. While the House bill included temporary increases, the Senate bill would permanently increase 9% credit allocations by 12% and permanently reduce the bond test for 4% credit deals to 25%, which will expand resources in bond-constrained states. The Senate bill did drop the temporary rural basis boost included by the House.
would be expanded. While the House bill included temporary increases, the Senate bill would permanently increase 9% credit allocations by 12% and permanently reduce the bond test for 4% credit deals to 25%, which will expand resources in bond-constrained states. The Senate bill did drop the temporary rural basis boost included by the House. 100% bonus depreciation would be restored.
would be restored. Section 179 business expensing limits would be increased for small businesses.
would be increased for small businesses. Opportunity Zones would be made permanent.
would be made permanent. The 1099 reporting threshold would be increased permanently to $2,000 and indexed for inflation starting for 2025.
State and Local Tax Deduction for Individuals and Pass-Through Businesses
The House-passed bill would increase the controversial limit on state and local tax (SALT) deductions for individuals from the current $10,000 to $40,000. This increase was part of a last-minute deal with Republicans representing high-cost and high-tax states which paved the way to passage of the bill in the House by a narrow 215 to 214 vote.
Senate Republicans do not support the SALT cap increase included in the House bill, but also recognize that changing the deal risks killing the bill in the House. Any changes to the House-passed bill by the Senate will require approval by the House.
Pending the outcome of negotiations in the Senate over the SALT cap, the Senate Finance Committee text includes the current law $10,000 cap as a placeholder.
The Senate bill also alters the treatment of so-called “SALT workarounds” adopted by most states with a state income tax. Known as a pass-through entity tax (PTET), this elective mechanism allows owners of pass-through entities to pay state income taxes at the entity level to avoid the SALT cap limitation.
The IRS blessed these arrangements in IRS Notice 2020-75. The House-passed bill would rescind the IRS notice, effectively ending the SALT workaround, but creates an exemption for certain business entities: builders and remodelers would generally still be allowed to deduct a PTET, while lawyers, accountants and consultants would not.
The Senate bill takes a different approach to these SALT workarounds, imposing a limit on the deduction rather than a repeal. In general, pass-through business owners would be able to deduct the individual SALT deduction plus an additional $40,000 in PTET allocations, or 50% of PTET allocations, whichever is greater.
Energy Tax Credits
Like the House bill, the Senate version proposes to end several energy tax credits used in the housing industry, though the Senate plan would provide a longer sunset period than the House for many of the energy tax provisions:
Senate bill would raise value of tax credit to use captured CO2 to produce more oil
Senate panel proposes making the tax credit for capturing carbon emissions for recovering oil equal to the $85/metric ton credit for burying those emissions underground. Change reflects a proposal made by Wyoming Senator John Barrasso. The House of Representatives version of the bill that passed by one vote last month left the credit for enhanced oil recovery projects at $60/metic ton. Under the IRA, former President Joe Biden’s signature climate law, tax credits for permanent removal had a higher value than for EOR because of concerns that carbon capture technologies would encourage oil drilling.
WASHINGTON (Reuters) -A U.S. Senate panel proposed making the tax credit for capturing carbon emissions for recovering oil equal to the $85/metric ton tax credit for permanently burying those emissions underground, a boon for oil and gas producers.
The finance committee proposed the change to the so-called 45Q tax credit, which was part of the 2022 Inflation Reduction Act, in its draft bill that forms a central part of the sprawling Republican budget package. The House of Representatives version of the bill that passed by one vote last month in that chamber left the credit for enhanced oil recovery projects at $60/metric ton.
The change reflects a proposal made by Wyoming Senator John Barrasso, a Republican, to put EOR projects at parity with carbon sequestration that got support from senators from other oil-producing states like North Dakota and Louisiana.
Under the IRA, former President Joe Biden’s signature climate law, tax credits for permanent removal had a higher value than for EOR because of concerns that carbon capture and direct air capture technologies would encourage oil companies to keep drilling for oil, undermining the fight to limit emissions linked to global warming.
Occidental, which has two direct air capture projects in Texas, is planning to permanently remove carbon and store it underground and use CO2 to recover oil, which it says makes the barrels more environmentally friendly.
Occidental declined to comment on the Senate change. The Carbon Utilization Research Council, which Occidental chairs, welcomed the decision to put EOR at parity with sequestration.
“As production matures with current recovery methods, there is critical need for large-scale injection in formations which will need billions of tons of CO2 captured from industrial sources to sustain oil and gas production with EOR,” said Shannon Angielski, executive director of CURC, adding that the barrels of oil produced would be lower carbon intensity.
Carbon removal advocacy group Carbon180 said it could risk pulling investment more toward fossil fuel production.
“Federal policy should prioritize durable carbon removal projects that can create prosperity for communities across the country — not expanded oil production,” said Carbon180 director Erin Burns.
Other oil companies involved in carbon capture and DAC include Exxon and Chevron.
Sasha Mackler, global policy & advocacy for ExxonMobil Low Carbon Solutions, told Reuters that the company did not lobby for bringing the EOR tax credit to parity with carbon sequestration.
(Reporting by Valerie Volcovici in Washington and Sheila Dang in Houston; Editing by David Gregorio)
The Child Tax Credit to Be Expanded, While the Solar Tax Credit Could Be Eliminated
The Child Tax Credit (CTC) is a tax incentive available throughout the U.S. that allows families with children under 17 to deduct up to $2,000 per child from their federal taxes. A new bill, sponsored by Republicans in the House of Representatives and recently passed, seeks to significantly boost this tax credit. But its design leaves out millions of the most vulnerable children. The Senate is also proposing to accelerate the demise of solar tax credits at an alarming rate. While solar and wind are “intermittent punished” with immediate cuts, hydroelectric, geothermal and nuclear energy would receive a significant extension until the end of 2025, truncating the planned deadline by 180 days after the bill is passed and signed into law. The proposed wind tax credits would be reduced to 60% of their current value by 2026. For home solar installations, the blow is even swifter and even more swifter, and the credit is even more significant until 2036, until the planned deadlines are passed.
The CTC is a tax incentive available throughout the U.S. that allows families with children under 17 to deduct up to $2,000 per child from their federal taxes, under current law. The goal of this support is to ease the financial burden on middle-class and low-income families.
Two tax credit policies are being debated in the Senate: Here’s what could happen
The initiative has three fundamental pillars:
Consolidate the Current: Make permanent the current $2,000 child credit, an amount initially established in the 2017 tax reform (during the Trump administration). Temporarily Increase: Raise the maximum credit to $2,500 per child under age 17 for a specified period: from 2025 to 2028. Future Protection: Starting in 2028, automatically adjust (index) the value of the loan based on inflation, so it doesn’t lose purchasing power over time.
Advocates, led by figures like Representative Jason Smith (Republican from Missouri), argue that this increase is essential. They underscore the enormous financial burden that working families face today, with childcare costs that have soared more than 200% in three decades—even surpassing college tuition in many states—and housing becoming less affordable. Smith calls the CTC “a critical investment in America’s future workforce.”
To access the full credit ($2,500 during the increase period), three basic requirements must be met:
Age: Children must be under 17 years old.
Identification: Must have a valid Social Security Number (SSN).
Income: The credit begins to phase out for taxpayers with adjusted gross incomes (AGI) above $400,000 (married filing jointly) or $200,000 (single or head of household).
We must emphasize emphatically where it says “refundable.” In 2025, $1,700 of the credit would be refundable, meaning families could receive that money even if they don’t owe taxes.
However, here’s the big stumbling block for those with the lowest incomes: this refundable component only increases by 15% for every dollar of income above $2,500. This formula makes it extremely difficult, if not impossible, for households with very low or no income to receive the full $1,700 credit, let alone the increase to $2,500.
Who will not be able to claim the expanded CTC
Herein lies the main criticism of the bill. Policy experts estimate that around 17 million children currently do not receive the full $2,000 benefit due to limitations in the reimbursable component. The new expansion does not address this fundamental problem:
Families with no taxable income or very low taxable income will not benefit from the proposed increase.
An estimated 4.5 million children who are U.S. citizens or legal residents could lose all eligibility if their parents do not have an SSN (even if the child does).
The Senate Threatens to Cut Residential Tax Credits
While one tax credit is growing (albeit with limitations), another crucial to the energy transition faces drastic and premature cuts. Tax incentives for residential solar energy, a pillar of the Inflation Relief Act (IRA) of 2022, are in the Senate’s sights, proposing to accelerate their demise at an alarming rate.
These solar tax credits allow homeowners to deduct a significant percentage of the cost of installing solar panels on their homes directly from their federal tax bill. Under current law (IRA), they were scheduled to remain strong and begin phasing out only in 2032. This long-term framework was designed to provide stability and encourage continued investment in clean energy.
However, a recent proposal from the Senate Finance Committee, introduced as part of a broader fiscal package on June 16, 2025, would radically change the rules of the game:
Accelerated Cut: Solar (and wind) energy credits would be reduced to 60% of their current value by 2026. Premature Death: These credits would be completely phased out by 2028, four years earlier than originally planned! Direct Hit to Residential: For home solar installations, the blow is even swifter and harsher: the credit would expire 180 days after the bill is passed and signed into law, abruptly truncating the planned deadline until the end of 2025.
What adds controversy is the contrast with the proposed treatment of other renewable energy sources. While solar and wind (considered more “intermittent”) are punished with immediate cuts, credits for hydroelectric, geothermal, and nuclear energy would receive a significant extension until 2036, maintaining 100% of their value until 2033 and gradually reducing only afterward.
This disparity has led to criticism that traditional or more consistent energy sources may favor energy, and American families seeking more eco-friendly, clean-energy homes could be affected.
Source: https://www.housingfinance.com/policy-legislation/senate-bill-proposes-permanent-lihtc-expansion/