President Biden has released his proposed budget for the 2025 fiscal year, including numerous tax provisions affecting both businesses 和 individual taxpayers. While most of these provisions have little chance of coming to fruition while the U.S. 众议院仍由共和党控制, they might gain new life depending on the outcome of the November elections. 以下是对该专业的概述 税收的提议 包括在预算中.
营业税规定
的 budget proposal includes many changes that could affect businesses’ tax outlook, 其中有几位拜登此前曾表示支持. 其中最引人注目的是:
公司税率. 根据这项提案，税率为 C公司 would increase from 21% to 28% — still below the 35% rate that was in effect before the 减税和就业法案 (TCJA). 的 effective global intangible low-taxed income (GILTI) rate would increase to 14%, 和 additional proposed changes would further increase the effective GILTI rate to 21%. 的 corporate alternative minimum tax rate would go up to 21%, from 15%.
高管薪酬. Biden proposes extending the current limitation on the deductibility of compensation in excess of $1 million for certain executives in publicly owned C公司 to privately held C公司. A new aggregation rule would treat all members of a controlled group as a single employer for purposes of determining covered executives.
超额业务损失(EBL)限制. 下 减税和就业法案, noncorporate taxpayers can apply their business losses to offset only business-related income or gain, 此外，2024年还有一个经通胀调整后的门槛, $305,000 or $610,如共同申请，则为5,000元). 的 proposal would make this limitation permanent 和 treat EBLs carried forward from the prior year as current-year business losses rather than as net operating loss deductions.
股票回购消费税. 的 通货膨胀消减法 created a 1% excise tax on the fair market value when corporations repurchase their stock to reduce the difference in the tax treatment of buybacks 和 dividends. 该提案将把税率提高四倍，达到4%. It also would extend the tax to the acquisition of an applicable foreign corporation by certain affiliates of the corporation.
相似种类的交流. Owners of certain real property can defer the taxable gain on the exchange of the property for real property of a “like-kind.” 的 proposal would allow the deferral of gain up to an aggregate amount of $500,000 for each taxpayer ($1 million for joint filers) each year for real property like-kind exchanges. (其他类型的资产不符合条件.) Excess like-kind gains would be recognized in the year the taxpayer transfers the real property.
个人税收规定
Biden continues to promise that he won’t raise taxes on filers earning less than $400,000 annually but opposes extending tax cuts for those making more than that amount. 除其他事项外，他的预算提案将影响:
税率. 的 proposal would return the top individual marginal income tax rate for single filers earning more than $400,000 ($450,000(联合申报人)，而tcja之前的比率为39.6%.
净投资所得税(NIIT). 收入超过400美元,000 would include all pass-through business income not otherwise covered by the NIIT or self-employment tax. 的 budget also would increase both the additional Medicare tax rate (on earnings above $400,000美元)和NIIT税率(投资收入超过400美元),000) to 5%.
资本利得税. Individuals with taxable income exceeding $1 million would see capital gains taxed at ordinary income rates, 高于目前最高的20%资本利得税. 也, 死亡时未实现的收益将被征税, subject to a $5 million exemption ($10 million for married couples).
儿童税收抵免(CTC). 该提案将把每个孩子的最高抵免额提高到3美元,6岁以下符合条件的儿童600美元，外加3美元,000 for all other qualifying children — 和 increase the maximum age to 17, 到2025年. 它还将实施每月预付计划, establish a “presumptive eligibility” concept 和 permanently make the CTC fully refundable.
保费税收抵免(ptc). Biden would make permanent the IRA’s expansion of health insurance subsidies to taxpayers with household income above 400% of the federal poverty line, as well as the reduction in the amount of household income that must be contributed to qualify for PTCs.
赠与税和遗产税. 该提案将关闭几个 赠与税及遗产税 帮助富人减税的漏洞. 例如, certain transfers would be subject to a new annual gift tax exclusion, 即捐款人的汇款总额超过50美元,000 in a year would be taxable regardless of whether the total gifts to each individual recipient didn’t exceed the annual gift exclusion amount ($18,(2024年).
税收改革正以这样或那样的方式到来
即使这些条款都没有按照提议颁布, 有关税收的新立法可能会在未来一两年出台. 事实上, 缺席国会行动, 许多重要的TCJA条款计划在2025年之后到期. Extensive tax debates 和 negotiations will likely soon take center stage. 请关注我们的最新进展.
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