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Which specific tax provisions did the OBBB sign or support that were made permanent and which applied primarily to high-income earners?
Executive summary
The One Big Beautiful Bill (OBBB) made many 2017 Tax Cuts and Jobs Act (TCJA) individual and business provisions permanent — including lower individual rate structure, the 20% qualified business income (QBI) deduction, full expensing/bonus depreciation and several international-business deductions — while also adding new deductions and temporary benefits that often favor higher‑income filers (e.g., the permanent lower top rates and preservation of deductions that scale with taxable income) [1] [2] [3]. Available sources list specific permanent provisions and note special phase‑outs or limits that “primarily” affect high earners (for example, SALT increases phased out at high incomes or AMT/exemption rules that target higher incomes) [4] [5].
1. What the OBBB made permanent: the headline TCJA carryovers
The OBBB locks in many TCJA individual tax elements that were set to expire, most notably maintaining the post‑2017 individual tax rate structure and the doubled standard deduction as permanent features; it also makes permanent business provisions such as full expensing (bonus depreciation) for many kinds of investment and the 20% qualified business income (QBI) deduction for pass‑through owners [1] [3] [2].
2. Specific permanent provisions often cited by tax shops and analysts
Commentaries and firm guides list concrete, permanent changes: the preservation of the 20% QBI deduction for eligible pass‑through income [2]; making permanent the TCJA’s reduced individual rates and bracket structure with inflation adjustments [1] [6]; and codifying permanent full expensing rules and other business tax fixes [3] [7]. Legal and tax advisories also note permanent changes to international‑tax deductions (NCTI/FDDEI percentages) and the reversion of business interest limitations to the EBITDA base permanently [8] [9].
3. Provisions made permanent that tend to help higher‑income taxpayers
Several of the permanent rules create larger dollar benefits for higher‑income filers because they are deductions or rate reductions that scale with taxable income: permanent lower top individual rates and brackets reduce marginal tax on high incomes relative to pre‑TCJA law; deductions like QBI (20%) yield larger tax savings at higher incomes and for larger business owners; full expensing/bonus depreciation accelerates write‑offs for substantial capital investors — typically larger firms or wealthy owners — and therefore disproportionately benefits higher earners [2] [3] [7].
4. SALT and carve‑outs: a targeted tempering that still aids higher‑tax states
OBBB temporarily raises the SALT cap to $40,000 for 2025–2029 (with phase‑out rules for very high incomes), but that increase is not permanent and reverts to $10,000 after 2029; several sources say the SALT increase is phased out for taxpayers above specified high‑income thresholds [10] [4] [11]. That temporary boost helps taxpayers in high‑tax states — often higher earners — but the phase‑out and sunset limit its permanent redistributive effect [4].
5. AMT, exemptions and charitable limits: mechanics that concentrate effects at the top
The OBBB preserves TCJA AMT exemptions and related rules that are calibrated to keep many middle‑income taxpayers out of AMT while continuing a backup tax that primarily falls on higher incomes; tax‑advisor summaries also flag new floors/caps on charitable deductions that mean timing matters for large donors [5]. These changes show the law’s design: preserve broad rate and deduction reductions while keeping targeted anti‑avoidance or cap rules that bite chiefly at higher incomes [5].
6. New deductions that look progressive by name but regressive by value
New or expanded items — such as deductions for tipped income, overtime, and a senior deduction for taxpayers 65+ — are temporary in some cases and function as deductions rather than credits; because deductions reduce taxable income, their tax‑value rises with marginal tax rates, so the largest dollar benefit flows to those in higher brackets even though the policy is framed as helping workers or retirees [12] [13] [14].
7. What the reporting does not say or leaves ambiguous
Available sources do not provide a single, exhaustive list in one place of every provision flagged “permanent” versus temporary nor a full numerical distribution of who benefits dollar‑for‑dollar; instead, law firms, the Tax Foundation, and tax‑service firms each emphasize different permanent items [3] [1] [2]. For precise, filer‑level impact or an authoritative table of permanent vs. temporary items, consult the Joint Committee on Taxation or the statutory text (not included in this packet of reporting) — current reporting summarizes but does not publish a single definitive master list here [15].
8. Bottom line — who gains most?
The OBBB cements broad rate reductions and deductions that create larger absolute tax savings for higher‑income taxpayers (permanent lower rates, QBI, full expensing) while adding some targeted relief for workers and seniors; some measures (e.g., SALT increase) help those in high‑tax states but are temporary or phased out at high incomes [3] [2] [4]. Reporting is consistent that the largest dollar gains accrue to higher earners, though many middle‑income filers also see tax changes through the preserved standard deduction and child‑credit adjustments [16] [1].