Fact check: What specific tax loopholes will the big beautiful bill address in 2025?

1. The headline: who wins and what feels like a win — permanent pass‑through relief and estate sheltering

The Act makes the Section 199A pass‑through deduction more durable by increasing and permanently codifying the qualified business income deduction, a move advisors call a major benefit for small businesses and owners of S corporations and partnerships ^{[1] [3]}. Simultaneously, the legislation raises the estate and gift tax exemption to $15 million per person, indexed for inflation, which estate planners say provides certainty and significantly reduces taxable estates for wealthy households ^[4]. These two provisions function as large, explicit benefits that many commentators describe as structural tax relief rather than narrow “loophole” closures, shifting the landscape for both intergenerational wealth transfer and business tax planning ^{[1] [3]}.

2. New individual deductions that look like policy priorities — tips, overtime, and vehicle buyers

The law introduces several new itemized or targeted deductions aimed at defined constituencies: tip earners, overtime workers, vehicle purchasers, and seniors, with specific income limits and phase‑outs described by tax commentators ^{[5] [2]}. These provisions are framed as relief measures and create distinct carve‑outs rather than broad base‑broadening reforms; analysts note the structure resembles policy tradeoffs rather than technical loophole closures because they add preferential treatments for certain activities and demographics ^{[5] [2]}. Tax planners warn these new deductions will generate planning opportunities and potentially new compliance complexities for payroll and retail sectors ^[5].

3. Capital gains: retained preferential rates at low incomes, not a wholesale loophole fix

The bill leaves in place 0% long‑term capital gains treatment for taxpayers below specific taxable income thresholds — $48,350 single or $96,700 married filing jointly in the guidance cited — which commentators highlight as continued low‑rate treatment rather than a newly targeted loophole closure ^[6]. Coverage by tax writers explains this retention benefits lower‑to‑moderate income investors and can be positioned as continuity of existing tax policy; however, the Act’s materials and summaries do not list new mechanisms to eliminate preferential capital‑gains strategies used by high‑income taxpayers, meaning major loopholes tied to timing, valuation, and entity planning remain subject to continued interpretation ^{[6] [7]}.

4. International provisions and corporate‑global tax changes — complexity without a single headline

OBBBA includes modifications to international tax rules, such as adjustments to global intangible low‑taxed income (GILTI) and changes resembling a remittance tax, which affect multinational groups’ effective rates and repatriation behavior ^{[7] [1]}. These provisions are technical and often shape multinational planning more than clear “loophole” closures; practitioners describe them as rebalancing international rules while leaving room for cross‑border tax arbitrage through treaty, transfer pricing, and entity‑level structuring, meaning some classic avoidance channels will require separate regulatory or IRS guidance to be fully addressed ^{[1] [7]}.

5. What proponents say versus what advisers warn — permanence and uncertainty

Supporters emphasize that the Act provides permanence to key tax attributes and predictable thresholds, enabling longer‑term compliance and planning by taxpayers and advisors ^{[1] [3]}. By contrast, law firms and commentators caution that permanence for certain provisions simply converts short‑term fixes into entrenched tax preferences, creating new planning landscapes ripe for creative structuring; they also note the Act frequently supplies frameworks without enumerating which traditional “loopholes” are being eliminated, leaving the IRS and courts to resolve many issues ^{[3] [2]}.

6. Who’s framing the conversation — law firms, tax shops, and policy advocates with distinct agendas

Coverage in the material comes primarily from tax boutiques, accounting firms, and estate‑planning advisories, each emphasizing angles that serve clients: estate planning certainty, pass‑through benefits, or operational guidance for businesses ^{[3] [8] [5]}. These actors often present the Act as favorable or manageable for their client bases, which creates potential agenda signals — promoters of the law highlight benefits, while some tax commentators stress the lack of targeted loophole closures. Independent commentators and policy voices are less represented in the provided analyses, which means readers should weigh commercial incentives when interpreting the practical import of each change ^{[8] [3]}.

7. Bottom line: many new benefits, few explicit loophole eliminations — watch IRS guidance

The One Big Beautiful Bill Act enacts broad, beneficiary‑focused changes (permanent §199A-style relief, $15 million estate exemption, new targeted deductions, international tweaks) rather than a clause‑by‑clause assault on historic tax avoidance techniques; the published analyses consistently show the law provides certainty and new opportunities but does not produce a single comprehensive list of “loopholes” closed in 2025 ^{[4] [2]}. Practitioners advise monitoring forthcoming IRS regulations and litigation for the real enforcement and interpretive actions that will determine whether long‑standing avoidance strategies are effectively curtailed or persist under new law ^{[1] [7]}.