Late in July, Senator Joe Manchin (D-WV) announced that he had reached an agreement with Senate Majority Leader Chuck Schumer (D-NY) on a budget reconciliation package that would replace the stalled Build Back Better legislation which had lacked Senator Manchin’s support (in part over his concerns of its impact on the federal deficit and its potential inflationary impact). 该协议涉及清洁能源、医疗保健和税收方面的倡议.
草案语言立法建议，命名为 Inflation Reduction Act of 2022 (爱尔兰共和军法案或法案)，在协议宣布后不久发布. 超过525页的税收条款包含在拟议的IRA法案的标题I中.
拟议的IRA法案税收条款第一章包括:
- Create a new corporate alternative minimum tax regime based on financial statement income (as adjusted for items including net operating loss carryovers) on corporations with profits exceeding $1 billion.
- 修改“附带权益”规则: (updated on 8/9/2022 Final Senate Version Eliminates the Change in Carried Interest Rules)
- Replace the three-year holding period with a five-year holding period requirement (with an exception for real property businesses) for taxpayers with adjusted gross income of $400,000;
- Expand the scope of income subject to the rules to include income from regulated futures contracts marked to market under IRC Section 1256, IRC第1231条规定的长期资本收益, and qualified dividend income;
- Expand, extend, and create numerous investment tax credits and production tax credits supporting green energy initiatives;
- Increase the research & development tax credit amount that can be claimed against payroll taxes for small businesses;
- 向国税局提供额外资金;
- 通过提议征收高达95%的消费税来激励处方药定价;
- 延长《bet9游戏平台》医疗保险保费税收抵免, including allowing higher-income households to qualify for the credits and boosting the subsidy for lower-income households, through the end of 2025.
Just as critical (for many taxpayers) as the tax provisions included in the proposed IRA Act are the tax provisions excluded from the Act contained in other proposed legislation such as the Build Back Better legislation that had passed the House of Representatives in 2021 (but had stalled in the Senate) (/our-thoughts-on/tax-reform-build-back-better-act-update) or proposals from other sources such as those included in the General Explanations of the Administration’s FY2023 Revenue Proposals (the so-called Greenbook) released in March 2022 (/our-thoughts-on/greenbook-2023-budget-revenue-and-tax-proposals).
《bet9平台游戏》中排除的提案包括以下内容
(虽然这不是一个完整的列表, it includes many proposals that have been floated at various times over the past 1½ – 2 years):
- Expansion of the 3.8% net investment income tax to include active flow-through income from partnerships and S corporations,
- The millionaire income surtax coupled with a separate increase to the highest individual marginal tax rate,
- 将公司税率从21%提高到28%，
- 以较高的普通所得税率对资本利得征税;
- Limitation on ability to utilize like-kind exchange provisions on sale of real estate; and
- Increasing the state and local income tax (SALT) deduction above the current limit of $10,000.
Finally, while the bill is moving forward, 仍然有一些障碍可能会延迟甚至阻止通行. These obstacles include:
- 参议院议员会批准这些条款吗? The bill is still being reviewed by the Senate Parliamentarian to ensure that it meets the rules required under the Senate reconciliation process.
- 亚利桑那州民主党参议员基尔斯滕·西内马(Kyrsten电影院)会投票支持这项法案吗? 目前尚不清楚参议员是否会对该法案投赞成票. All 50 Democratic senators need to support the bill (assuming no Republican senators decide to vote in favor of the bill). Further, senate vote must be in person and some senators might not be able to attend due to COVID restrictions (and, 取决于参议员所属的党派, 不出席可能会影响投票结果。.
- 是否有足够的民主党众议员支持该法案? Some Democratic party House of Representative members previously voicing opposition to any bill lacking an increase in the SALT deduction might now be on board, 在众议院提供足够的赞成票.
Many of the effective dates included in the proposed legislation are for tax years beginning after December 31, 2022.
如果您对拟议的IRA法案有疑问, 请联系您的施耐德唐斯税务顾问以获得更多见解.
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