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Columns at the Delaware County Court of Common Pleas, Media, Pennsylvania

From the Hill: May 13, 2025

This week's activities on the Hill include the House Ways and Means Committee passing its portion of the budget reconciliation bill.

Here’s a look at recent tax-related happenings on the Hill, including committee markup meetings and trade agreements in process with China and the United Kingdom.

Lately on the Hill

House Ways & Means Passes Tax Bill

The House Ways and Means Committee passed its portion of the budget reconciliation bill in a 26 to 19 vote. At the moment, the two remaining House committees, the Energy and Commerce Committee and the Agriculture Committee, are meeting to mark up their respective texts.

Notable tax provisions included within the Ways and Means Committee’s bill include an increase to the qualified business income deduction under Section 199A from 20% to 23% while making it permanent, rate reductions for global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII), and making permanent the unified estate and gift tax exemption increased to $15 million per taxpayer. The individual deduction limitation for state and local taxes is proposed to be increased to $15,000 for married persons filing separately earning up to $200,000 and $30,000 for all other filers earning up to $400,000.

With this development, Forvis Mazars’ Washington National Tax Office (WNTO) has released its legislative tracker providing up-to-date information as federal tax legislation is introduced in Congress. The legislation tracker can be accessed through the WNTO’s website. This tracker includes a description of the provision, its status in the legislative process, and insights into its application and potential impact.

The Energy and Commerce Committee and the Agriculture Committee are responsible for the majority of the $1.5 trillion in spending cuts House committees have been instructed to achieve at $880 billion and $230 billion, respectively. However, anything less than $2 trillion will have to come out of the Ways and Means Committee’s allocation of $4.5 trillion for tax cuts.

The spending cuts the two committees have been laden with are proving difficult to achieve as they will likely have to target social spending programs like Medicaid and the Supplemental Nutrition Assistance Program—avenues that have been unpopular among some Republicans.

Despite the cost-cutting conundrum, 32 Republican members of Congress reaffirmed their commitment to the reduction instructions. “The House reconciliation instructions are binding,” states the May 7 letter to Republican leadership, “They set a floor for savings, not a ceiling. We must hold that line on fiscal discipline to put the country back on a sustainable path. We are more committed than ever to making that happen.”

Once the remaining three committees complete their work, the House Budget Committee will assemble all legislative texts from the various committees with budget reconciliation instructions for a vote by the full House with hopes by Republican leadership that it passes by Memorial Day.

Trade Agreements in Process With China & the UK, Tariffs Coming for Foreign-Produced Films

A joint statement between the U.S. and China on trade was released on May 12, 2025, following discussions between the countries in Geneva. The statement provides that as of May 14, 2025, the trading partners will suspend, for 90 days, tariffs in excess of 10% imposed after April 2, 2025. The other 20% tariffs the U.S. has imposed on China will remain in place, bringing the total tariffs on China to 30%. According to the statement, “After taking the aforementioned actions, the Parties will establish a mechanism to continue discussions about economic and trade relations.” The White House released an executive order to implement the agreed-upon terms. 

The White House released a trade agreement framework that the U.S. and the United Kingdom have agreed upon. A fact sheet provided by the Office of the United States Trade Representative summarizes key propositions, including increased access for U.S. farmers, ranchers, and producers into the U.K., decreased tariffs on U.K. auto imports, and a “new trading relationship for steel and aluminum between our countries.” A 10% baseline tariff will remain on imports to the U.S. with certain exceptions.1

Last week, President Donald Trump announced intentions to impose a 100% tariff on movies filmed or produced outside the U.S. in an effort to boost the country’s film industry.2 Shortly after the announcement, California Gov. Gavin Newsom expressed his support, “We’re eager to partner with the Trump administration to further strengthen domestic production and Make America Film Again.” The governor also proposed $7.5 billion in federal tax credits to incentivize domestic production.3

Government Funding to Dry Up in August

Last Friday, Treasury Secretary Scott Bessent issued an open letter to Speaker Mike Johnson (R-LA) notifying him that extraordinary measures currently funding the government are expected to run out in August, while Congress is expected to be in recess. He therefore urged Congress to “increase or suspend the debt limit by mid-July, before its scheduled break, to protect the full faith and credit of the United States.”

Republican lawmakers in both the House and Senate passed budget resolution provisions to increase the debt limit by $4 trillion and $5 trillion, respectively. By including the debt limit increases within the budget reconciliation process, the maneuver would allow them to pass the provision without support from the Democrats. However, if the budget reconciliation passes with such a provision, it would be the first time for many Republican congressional members in the House and Senate to vote for a debt increase.

The time frame to pass the budget reconciliation measure and increase the debt limit falls in line with Republican leadership’s goal to have the legislation done by July 4.

From the Treasury & IRS

Outstanding ERC Claims Cut in Half

The IRS “has made significant progress on the backlog of [Employee Retention Credit (ERC)] claims,” according to the National Taxpayer Advocate. Although more than 597,000 claims remain unprocessed, this figure is approximately half of the 1.2 million outstanding claims reported as of October 2024.4 The Taxpayer Advocate Service anticipates it will take the remainder of the year to process the rest of the claims. On April 15, 2025, the filing period for new claims officially closed.

Released Guidance

Revenue Procedure (Rev. Proc.) 2025-21 modifies Rev. Proc. 2024-32 and provides immediate relief of certain requirements for sponsors of a defined benefit plan to request approval from the IRS to use new plan-specific substitute mortality tables.

The State Tax Brief

Arkansas: Senate Bill 567 was enacted, changing the state’s sales sourcing laws, other than sales of tangible personal property, from a “cost of performance” approach to “market sourcing.” The change applies for tax years beginning on or after January 1, 2026. The legislation also amends nexus requirements for out-of-state businesses without a physical presence in the state. Such businesses will be deemed to have nexus if their Arkansas-sourced gross receipts exceed $250,000 in the current or immediately preceding tax year.

Kansas: Senate Bill 269 was enacted, implementing significant tax reform to the state. The bill provides for a reduced corporate tax rate deduction at the end of fiscal year 2028 assuming corporate tax receipts exceed the prior year’s receipts. Furthermore, the state’s apportionment calculation has been changed from a three-factor formula to a single sales factor for multistate corporations and financial institutions.

Tackling Tax

Be sure to catch our new show “Tackling Tax,” where we’ll bring you the latest on tax policy and strategies.

This newsletter features developing content that is subject to change at any time. It does not constitute legal or tax advice. Consult your professional advisors prior to acting on the information set forth herein. 

  • 1“Trump’s Scant UK Deal Shows Limits of Frenzied Trade Strategy,” bloomberglaw.com, May 8, 2025.
  • 2“Netflix, Disney Shares Slip on Tariff Plans for Foreign Films,” bloomberglaw.com, May 5, 2025.
  • 3“Gavin Newsom Seeks $7.5 Billion Hollywood Aid, Trump Accord,” bloomberglaw.com, May 5, 2025.
  • 4“IRS Sits on 1.2 Million Covid-Era Claims as Filing Season Nears,” bloomberglaw.com, January 8, 2025.

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