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Amends 26 U.S.C. 702(a) by adding a new paragraph (9) to require that any amount treated as ordinary income or loss under subsection (a), (b), or (e) of new section 710 be taken into account separately by a partner.
In subsection (c) of 26 U.S.C. 83, redesignates existing paragraph (4) as paragraph (5) and inserts a new paragraph (4) that provides special rules for transfers of partnership interests in connection with the performance of services, including a specific valuation rule and an election rule.
Adds new section 225, 'Qualified overtime compensation,' allowing a deduction equal to qualified overtime compensation for the taxable year, defines 'modified adjusted gross income' (including increase by amounts excluded under sections 911, 931, 933), sets income-based limitation amounts, and defines 'qualified overtime compensation' as overtime paid as required under section 7 of the Fair Labor Standards Act in excess of the regular rate, excluding amounts deducted under section 224.
Redesignates the existing section 225 as section 226 and updates the table of sections for part VII of subchapter B of chapter 1 accordingly.
Amends section 63(b) to add the deduction provided in new section 225 to the list of items in subsection (b).
Amends section 6051(a) (information required on Forms W-2) by inserting a new paragraph (18) requiring reporting of the total amount of qualified overtime compensation as defined in new section 225(b).
Adds a new subsection (g) 'Termination' to 26 U.S.C. §86 providing that the section shall not apply to any taxable year beginning after December 31, 2025.
Adds new section 224 to subtitle A, chapter 1 (Part VII of subchapter B) titled 'Cash tips', allowing a deduction equal to cash tips included on statements furnished to the employer under section 6053(a), and establishing a limitation based on modified adjusted gross income and a definition of modified adjusted gross income.
Creates several tax code changes: allows a new deduction for cash tips reported to employers, allows a deduction for qualified overtime pay above the regular rate, excludes Social Security benefits from taxable income, and changes partnership tax rules for service-based partnership interests (valuation, default election rules, and special tax treatment for investment-manager partnership interests). Most income-tax changes apply to tax years beginning after December 31, 2025; partnership provisions apply to transfers or holdings after the Act becomes law and add new reporting and rulemaking requirements for Treasury and the IRS.
Referred to the House Committee on Ways and Means.
Introduced April 3, 2025 by Stephen Cohen · Last progress April 3, 2025