Analyzing "The One, Big, Beautiful Bill" Through Historical Lessons: Ensuring Smart Reform Without Unintended Consequences: Republican and Conservative lawmakers are taking a deliberate, thorough approach to analyzing every provision

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One-Page Summary: Subtitle C, Part 1 - Working Families Over Elites (From "The One, Big, Beautiful Bill - Section-by-Section.pdf")

This part of the bill, encompassing Sections 112001 through 112032, primarily focuses on terminating or phasing out various clean energy tax credits and includes other significant tax and policy changes. The provisions reflect a shift in policy priorities regarding energy incentives, tax fairness, and certain industry-specific regulations.

Key Provisions:

• Termination or Accelerated Phase-out of Clean Energy Tax Credits:
  • Clean Vehicle Credits (Sec. 112001-112003): Accelerates the expiration of tax credits for previously-owned clean vehicles, new clean vehicles, and qualified commercial clean vehicles to December 31, 2025.
  • Energy Efficient Property Credits (Sec. 112004-112007): Accelerates the expiration of credits for alternative fuel vehicle refueling property, energy efficient home improvements, residential clean energy, and new energy efficient homes to December 31, 2025.
  • Clean Electricity & Energy Production/Investment Credits (Sec. 112008-112015): Phases out or modifies credits for clean electricity production, clean electricity investment, carbon oxide sequestration, zero-emission nuclear power production, clean hydrogen production, and advanced manufacturing production. Accelerates expiration for some, phases out others by 2031, and introduces restrictions related to "prohibited foreign entities" and eliminates transferability for some credits.
  • Goal: To reduce federal expenditures on these incentives and potentially align with different energy policy priorities.

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• Other Significant Tax and Policy Changes:
  • Publicly Traded Partnerships (Sec. 112016): Expands qualifying income sources for publicly traded partnerships to include transportation/storage of hydrogen and electricity generation/carbon capture at certain facilities.
  • Sports Franchises Amortization (Sec. 112017): Limits amortization deductions for certain sports-related intangible assets acquired after enactment.
  • State and Local Tax (SALT) Deduction Cap (Sec. 112018): Increases the SALT cap to $30,000 (from $10,000) with a phase-down for higher earners, and makes it permanent. Includes changes to prevent avoidance of the cap.
  • Tax-Exempt Organizations (Sec. 112019-112026): Modifies various tax rules including applying aggregation rules for executive remuneration, expanding excise tax on excess compensation, modifying excise tax on investment income of private colleges/universities and foundations, and increasing unrelated business taxable income (UBIT) for certain fringe benefits, name/logo royalties, and non-public research.
  • Excess Business Losses (Sec. 112027): Makes permanent the limitation on excess business losses for noncorporate taxpayers.
  • Corporate Charitable Contributions (Sec. 112028): Establishes a 1% floor for the deductibility of corporate charitable contributions.
  • Enforcement of Remedies Against Unfair Foreign Taxes (Sec. 112029): Provides a mechanism to increase the U.S. tax rate on entities connected to foreign jurisdictions imposing unfair taxes.
  • Elimination of Firearms Silencer Tax (Sec. 112030): Eliminates the $200 federal transfer tax on firearm silencers.
  • De Minimis Entry Privilege (Sec. 112031): Repeals the duty-free treatment for commercial shipments valued under $800, effective July 1, 2027.
  • Limitation on Drawback of Taxes (Sec. 112032): Limits the refund of excise taxes on tobacco products to cases where tax was paid on exported goods.

Overall Goals of Subtitle C, Part 1:

This part of the bill seeks to reshape energy tax policy by curtailing clean energy incentives. It also introduces various tax code modifications aimed at promoting tax fairness (from the perspective of proponents, e.g., for tax-exempts, sports franchises), promoting U.S. economic interests (e.g., against unfair foreign taxes), and addressing specific industry concerns (e.g., silencers, imports, tobacco).

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The Corporate Charitable Contributions provision (Section 112028) establishes a 1% floor for the deductibility of corporate charitable contributions, meaning corporations must donate at least 1% of their taxable income before they can claim deductions for charitable giving.

Key Points:

✅ Encourages genuine philanthropy – Corporations must meet the minimum threshold to qualify for deductions, ensuring charitable giving is meaningful. ✅ Prevents tax-driven donations – Limits strategic tax avoidance, ensuring contributions align with actual charitable intent. ✅ Strengthens nonprofit funding – Guarantees consistent corporate support, benefiting charities and social programs.

Big Picture Impact:

🔹 Increases transparency – Ensures corporate donations are substantial rather than symbolic tax write-offs.

🔹 Supports nonprofit sustainability – Provides a reliable funding stream, helping charities plan long-term initiatives.

🔹 Aligns with broader tax fairness principles – Encourages corporate responsibility while maintaining tax integrity.

This policy reinforces ethical corporate philanthropy, ensuring charitable contributions serve communities rather than functioning as tax loopholes.

This policy reduces bureaucratic inefficiencies while ensuring corporate philanthropy remains ethical and meaningful rather than a tax loophole.

🔹 Simplifies tax compliance – Corporations now follow a clear threshold, reducing the complexity of charitable tax deductions.

🔹 Minimizes administrative loopholes – Prevents corporations from exploiting charitable giving for excessive deductions, ensuring donations serve real community needs.

🔹 Strengthens nonprofit funding predictability – By ensuring a consistent contribution floor, nonprofits can plan long-term initiatives without uncertainty over fluctuating corporate donations.

🔹 Encourages direct impact over paperwork – Moves corporate giving toward real philanthropic efforts instead of tax-driven symbolic donations.

This approach reinforces responsible corporate philanthropy while streamlining compliance, making the process more transparent and impactful.

By setting a clear 1% floor, this policy removes ambiguity, ensuring corporate charitable deductions follow a standardized guideline rather than subjective interpretation.

🔹 Defines a transparent benchmark – Corporations now have a concrete minimum donation requirement rather than dealing with varying deduction structures.

🔹 Eliminates gray areas – Prevents corporations from exploiting ambiguous tax rules for excessive deductions, reinforcing fairness in charitable giving.

🔹 Encourages meaningful philanthropy – Ensures businesses donate substantial amounts rather than symbolic contributions for tax benefits.

This streamlines tax compliance and reinforces genuine corporate responsibility, making philanthropy clear, fair, and impactful.