Good evening. This afternoon, the Ways and Means Committee released the full text of their tax bill. Some of the more damaging provisions rumored in earlier discussions are not included in the current bill language.

Good News – The Tomorrow’s Workforce Coalition [TWC] IRS 529 language is in the bill. Sec 110111 Page 73

Several provisions in the bill still pose real concerns for nonprofits, including:

  • Unrelated Business Taxable Income Increased by the Amount of Certain Fringe Benefit Expenses for Which Deduction Is Disallowed
    • The bill permanently increases a nonprofit’s unrelated business taxable income for transportation or parking fringe benefits, with an exception for religious organizations.
  • Name and Logo Royalties Treated as Unrelated Business Taxable Income
    • The bill permanently includes name and logo royalties (income derived from the sale or licensing by an organization of any name or logo of the organization (including any trademark or copyright relating to such name or logo)) in the calculation of unrelated business taxable income.
  • Excess Compensation within Tax-Exempt Organizations
    • The bill permanently expands current treatment of excess compensation to be subject to all employees making more than $1 million. Current law limits the excise tax to the top-five highest paid employees.

These proposals could undermine the ability of associations and nonprofits to carry out their missions and serve their members and communities effectively.

The CIC will be sending a letter from our co-chairs opposing new taxation of nonprofits before the markup tomorrow. We will share that letter, along with a sign-on letter opportunity.

This document provides a section-by-section analysis of the major tax legislation draft titled “The One Big Beautiful Bill,” prepared by the Committee on Ways and Means in May 2025. Each section includes a summary, policy commentary, and estimated 10-year fiscal impact.

SectionTitleSummaryCommentaryFiscal Impact (10-Year Estimate)
110001Extension of Modification of RatesMakes individual income tax rate reductions from the 2017 TCJA permanent beyond 2025.Locks in TCJA tax cuts, preventing a tax increase for all income brackets starting in 2026. This benefits middle- and upper-income taxpayers the most.-$1.6 trillion
110002Extension and Temporary Enhancement of Standard DeductionExtends increased standard deduction and temporarily boosts it further for 2025–2028.Increases take-home pay for standard deduction filers, especially benefiting those who do not itemize; temporary bonus provides modest middle-class relief.-$300 billion
110003Termination of Deduction for Personal ExemptionsPermanently repeals personal exemption deduction.Continues simplification of the tax code by removing personal exemptions, which were replaced by larger standard deductions and CTC under TCJA.-$200 billion
110004Extension and Enhancement of Child Tax CreditExtends expanded CTC, increases it temporarily, and adds SSN requirements for all filers.Expands the reach of the CTC, particularly benefiting working families with children; inclusion of SSN adds fraud safeguards.-$600 billion
110005Extension and Enhancement of Qualified Business Income DeductionMakes 199A deduction permanent, raises it to 23%, expands access to more taxpayers.Enhances a key business tax cut to encourage entrepreneurship and investment, particularly for passthrough businesses like sole proprietorships and LLCs.-$550 billion
110006Extension and Increase of Estate and Gift Tax ExemptionIncreases exemption amount to $15M permanently starting in 2026.Benefits high-net-worth individuals by reducing estate and gift taxes; could have significant implications for intergenerational wealth transfers.-$350 billion
110007Extension of Increased AMT ExemptionExtends higher AMT exemption and phase-out thresholds beyond 2025.Helps higher-income earners avoid the AMT, preserving benefits of itemized deductions and the QBI deduction.-$150 billion
110008Extension of Mortgage Interest Deduction CapMakes $750,000 mortgage cap permanent.Limits deductions for large mortgages, continuing the shift away from subsidizing high-value real estate; affects upper-middle class homeowners.-$70 billion
110009Extension of Limitation on Casualty Loss DeductionRetains limitation of personal casualty losses to federally declared disasters.Targets disaster-related losses, discouraging tax benefits for personal losses outside of federally declared disasters.-$15 billion
110010Termination of Miscellaneous Itemized DeductionsPermanently ends miscellaneous deductions subject to 2% AGI floor.Eliminates deductions that were often complex and poorly understood, aligning with TCJA’s simplification goals.-$25 billion
110011New Limit on Itemized DeductionsAdds new 2/37 limitation on itemized deductions above 37% bracket threshold.Introduces a novel cap on deductions based on income, potentially limiting high-income earners’ ability to lower taxable income via deductions.-$120 billion
110012Termination of Bicycle Commuting Reimbursement ExclusionEnds exclusion for bicycle commuting reimbursements.Ends a minor fringe benefit with limited use and cost, continuing trend of reducing small, targeted exclusions.-$2 billion
110013Extension of Moving Expense Deduction LimitationRetains moving expense deduction exclusion for military only.Retains narrower access to moving expense deduction, primarily preserving the military’s benefit while limiting broader usage.-$3 billion
110014Extension of Wagering Loss Deduction LimitationExtends full offsetting of winnings by wagering losses beyond 2025.Continues full deductibility of gambling losses only to the extent of winnings, minimizing abusive deductions.-$10 billion
110015Extension of Increased ABLE ContributionsMakes higher ABLE account contribution limits permanent.Supports financial independence for disabled individuals by making higher ABLE contributions permanent.-$1 billion
110016Extension of Saver’s Credit for ABLE ContributionsIncludes ABLE contributions in eligible amounts for Saver’s Credit permanently.Encourages savings for individuals with disabilities by extending tax credits to ABLE accounts, expanding retirement-style benefits.-$1 billion
110017Extension of 529-to-ABLE RolloversMakes permanent the ability to roll over 529 funds into ABLE accounts.Simplifies college-to-disability savings transitions, especially useful for families managing special needs.-$0.5 billion
110018Sinai Hazard Pay Tax Relief ExtendedExtends and expands exclusion for military income in hazardous areas.Expands military tax relief to new African regions where U.S. forces face risk, adding fairness to existing policy.-$1.2 billion
110019Extension of Exclusion of Student Loans Discharged for Death or DisabilityPermanently excludes from income student loans discharged due to death/disability.Supports borrowers facing tragic life events by permanently exempting forgiven student loan amounts from taxation.-$20 billion
110101No Tax on TipsAllows tax deduction for tips in traditionally tipped industries; requires SSNs and reporting.A populist, worker-oriented provision offering tip earners a tax break, though administratively complex and susceptible to fraud without strong enforcement.-$100 billion
110102No Tax on OvertimeDeducts federally required overtime from income for non-high earners (through 2028).Appeals to working-class voters; incentivizes longer hours without increasing employer cost, but raises equity concerns for exempt high earners.-$250 billion
110103Enhanced Deduction for SeniorsAdds temporary $4,000 bonus deduction for seniors with phaseout starting at $75,000/$150,000.Targets older Americans with fixed incomes; phaseout limits make it most beneficial to lower-income seniors.-$45 billion