PL119-21
I was recently asked to provide which sections or provisions were made specifically by Congress to give more tax breaks to the richest people in our country, while also outlining the specifics of instances money was actually taken from the larger majority of Americans. Specifically, those of us who’ve been toiling away, the heartbeat of this nation - the middle class. In this article, I’ll be going through all the provisions that have been used to cut taxes for the American Greed class, and I’ll be following up in the next few days with what programs have been chopped to bits or eliminated completely by the regime in an effort to balance this budget, despite giving all the rich bigger tax breaks, many more loopholes, and taking in far less from the super greedy so they can keep being greedier.
The One Big Beautiful Bill was signed into law on 4 July 2025, and became known and PL119-21, or Public Law 119-21. It is the specific piece of legislation that has been used to discriminate, other, belittle, or attack the marginalized of our country, as well as redesign our entire American politics, government, social program solutions and so on. I will illustrate where these provisions were made within the bill, and how we as Americans, tell the Supreme Court Justices, GOP Congress, this unconstitutional president, this bill and the lawmakers who wrote it to get bent if they think we’re not going to fight for our freedoms and against this bill.
PL119-21 created a blueprint toward fascism we warned everyone about. It outlines massive tax breaks for the richest people in our country, by focusing tax relief efforts specifically on aspects which would stand to only benefit those at the highest tier of income levels.
Pass Through Business Income Deductions.
Section 70105 permanently extends the Section 199A qualified business income deduction. Regular income is typically taxed the same for all of us. However, PL119-21 initiated a two tier system that allows pass-through business owners access to special lower marginal tax rates than workers. This two-tier system was created in 2017 (under Trump Version 1.0) in the Tax Cuts and Jobs Act of 2017. The 199A pass-through business deduction allows business owners to deduct 20% of their “qualified business income” on their taxes. This lowers taxes on their income by slightly more than 20%, compared with the tax rates on ordinary income. The summary of this is it makes marginal tax rates 20% lower for people with business income versus people working for wage income. This provision allows business owners to pay taxes at lower rates than their employees.
Permanent Top Marginal Income Tax Rate Cuts
Section 70101 made the tax rate cuts for the top 2% of American households permanent. These tax cuts were initially established under the 2017 Tax Cuts and Jobs Act. What this specifically did was to lower the tax rate for individuals who received income over $640,000 and above $768,000 for married couples. As I previously stated, this apples to only about 2% of our nation’s population, as most of us do not fall within this tax bracket. With that said, this specific provision locks in the rate the wealthiest are to be taxed at 37%. It would have reverted to 39.6% if this provision had not been made. On average, this provision alone will save those high income earners more than $10,000 a year. This provision alone with cost an estimated tax loss to the nation of about $340 billion through 2034.
Estate and Gift Tax Exemptions
Section 70106 permanently increased the federal estate, gift, and generation-skipping transfer tax exemptions to $15 million per individual. It had been previously set at $5 million. This means the wealthy can gift or will an extra $10 million to each of their heirs without a tax being levied. There are about 4,000 households this section pertains to, and in 2023 the federal government collected $24 billion from estate taxes that would have otherwise transferred from millionaires to millionaires at zero percent tax, all for a new income they did not earn. This provisional change under Section 70106 is expected to cost the nation about $212 billion in lost revenue between now and 2034.
Expansion of Investor Tax Shelters
Section 70431 of PL119-21 amended the provisions of IRC Section 1202 regarding Qualified Small Business Stock (QSBS) gain exclusions, caps, and asset thresholds. What this provision basically does is expand the ability for rich investors to earn money tax free. Let it be made clear that income from capital gains already receives special treatment by being taxed at lower rates than regular income. Also, specific types of capital gains can qualify to be exempt from tax entirely. PL119-21 expands on two of these capital gains exemptions. Initially, it reauthorizes the expiring Opportunity Zones exemption at a cost of lost revenue around $41 billion. This provision does away with taxes on income from specific “opportunity zones” that are to be held for at least 10 years. For reference, opportunity zones are permanently established tax incentive areas of our country which have been designed to spur private investment and job creation in economically distressed and rural communities. Secondly, PL119-21 increases the amount that can be exempted from tax under the Qualified Small Business Stock (QSBS) exemption by 50%, which will come at a cost of lost revenue of $17 billion. The QSBS exemption does away with taxes on investors in certain start up companies and allows $15 million or 10 times an investor’s basis (whichever is greater) to be excluded from capital gains after 5 years, with lesser amounts owed after just 3 or 4 years. Studies conducted by the United States Treasury Department have shown that the majority of capital gains go to people with total incomes of more than $1 million. Only about 1% of gains go to people with less than $100,000 in income. While there is no comprehensive data on who benefits the most from the Opportunity Zone exemption, beneficiary profiles are likely to be similar to those of QSBS beneficiaries because this is a tax bracket restricted to very savvy professional investors. Study by the Congressional Research Service notes that “economic theory would predict that tax subsidies for capital would not directly benefit workers” and programs such as these “tend to shift investment from one area to another, rather than result in a net increase in aggregate economic activity.” This was something I’ve alluded to in the past - aggregate economic activity, or as I’ve referred to it, the Velocity of Money. Instances like what has been legislated in the particulars of Section 70431 do nothing to help the economy as the money exchange doesn’t actually shift currency outside the realm of the richest tax bracket. This statement holds true for the vast majority of what was written into tax law within PL119-21.
International Business Tax Cuts
Under the Tax Cuts and Jobs Act of 2017, large tax cuts were given to businesses, and especially so for large foreign corporations. The biggest parts of this involved lowering the corporate tax rate from a maximum of 35% to 21% and moving the United States from a worldwide corporate tax system to one more territorial. Even though PL119-21 put less emphasis on corporate and business taxes than the previous 2017 TCJA, PL119-21 actually cut international business taxes more than the 2017 TCJA did. International corporate tax cuts and reforms comprise a significant proportion of PL119-21, and in fact have their own Subchapter B, titled Permanent America First International Tax Reforms. They cover Section 70311 to Section 70354. Key changes that were made in Subchapter B were made in regard to foreign tax credits in sections 70311-70313, in which the limitations and sourcing rules were changed. The specifics here dealt with reducing the Section 960(d) foreign tax disallowance (what the government had been taxing initially off the top, sometimes referred to as a “haircut”). These sections lowered that haircut from 20% to 10%. This allowed corporate shareholders to claim a 90% deemed paid audit instead of 80%. Essentially, PL119-21 cut taxes on foreign profits by $167 billion. In contrast, the 2017 TCJA made substantial cuts to taxes on foreign profits, incentivizing the offshoring of companies to reduce taxes. America first, eh? Just wait - it get’s better! This was paid for by a one time “transaction tax” and the promise that tax rates on overseas profits would be subjected to higher tax rates in later years. PL119-21 cancelled these provisions that promised to raise those specific tax rates. The end result was the lowering of corporate foreign taxed and the aspects which had been in place to raise them. It’s easy to see how the 2017 TCJA tax cuts benefited top earner corporate owners, so it is expected that the provisions in Sections 70311 through Sections 70354 will do the same, as the purpose was identical between The 2017 TCJA and PL119-21. It’s worth noting here that a team of researchers from the Joint Commission on Taxation and the Federal Reserve Board studied who benefitted from the corporate tax cuts, finding that “51% of gains flow to firm owners, 10% flow to executives, 38% flow to high paid workers, and 0% flows to low paid workers.
Special Interest Tax Breaks
On top of the past 5 provisions, PL119-21 made specific cuts in taxes for special industries. As you will see, these are comprised of the same corporations that typically lobby the hardest to get their grifts and big profit protocols enacted. Under Section 70104, banks and financial institutions were given significant carveouts. Specifically, it altered the rules for business interest expense limitations, reverting the baseline calculation back to an EBITDA - style framework. This means Earnings Before Interest, Taxes, Depreciation and Amortization. So what exactly does this do? It enables high leverage corporate structures to aggressively shield and deduct debt. While this impacts multiple industries, independent non-partisan tax analysis notes that non-financial businesses heavily utilizing these write offs mitigate deduction traps specifically by shifting capital and leasing physical assets directly from financial institutions and banks that maintain steady interest income. Section 70435 of PL119-21 cancelled another carveout for banks. It added Section 139L to the Internal Revenue Code, allowing qualified financial institutions to exclude 25% of the interest income earned from eligible loans secured by rural or agricultural real estate from their federally taxable income. Section 70427 addresses the federal excise tax on makers of distilled spirits. Instead of lowering the standard federal excise tax rate paid directly by domestic manufacturers, it made cuts in taxes levied on these distilleries by reinstating and making permanent the higher “cover over” rate of $13.25 per proof gallon (it had previously been $10.50). What is a cover over and why does this matter to distillers? The “cover over” rate is a specialized federal excise tax collected on rum and given back to the governments of Puerto Rico and the U.S. Virgin Islands. Instead of keeping the money in the United States Treasury, the federal government gives the money to these territories to support their local economies and rum industries. Why does this matter so much to rum distillers? It matters so much because these territorial governments typically just give the money directly to the companies making the rum. Government subsidized alcohol. It’s simple to see this as feeling less like a tax provision and more like a paycheck. Section 70439 of PL119-21 weakened the rules pertaining to Real Estate Investment Trusts (REIT’s) and their owners. By relaxing this restriction, REIT’s are able to focus a larger portion of their portfolios into higher-revenue, commercial operations. Because REIT’s are structural as pass through entities that directly distribute at least 90% of their taxable income to their owners to escape double corporate taxation, expanding their ability to generate and capture those operational profits directly increases the yield and cash distributions directly to their investors. Combined with the permanent extension of the Section 199A 20% pass through deduction for REIT dividends which I already highlighted as being enacted with Section 70105 of PL119-21, this maximizes the after-tax wealth retained by REIT sponsors and shareholders. Rich people getting richer, done with laws all within the same grift manifesto of PL119-21, aka The One Big Beautiful Bill. Tax breaks such as these generally just pad the pocketbooks of the business owners getting the tax breaks.
Domestic Corporate and Business Tax Cuts
Throughout the entirety of PL119-21, there are $753 billion in domestic business tax cuts, which is similar in scope to what had been previously cut for businesses in the 2017 TCJA, if adjusted for inflation (2017’s cuts were $650 billion in 2017 dollars). Many of the business tax cuts in PL119-21 come in the form of cutting taxes on investments businesses make, such as on research and development, equipment purchases, and some specific manufacturing and production systems. PL119-21 also gifted $61 billion in more generous deductions for business debt payments.
The benefits I have outlined here which were signed into law on 4 July 2025 primarily benefit the super wealthy business owners. There are some economists who will argue that lowering taxes on the wealthy corporate robber barons can increase investment.
Horseradish.
Those who continue to pitch these carveouts as being opportunities for owners to reinvest are the same hucksters who tried to sell us on trickle-down Regan-omics for the past 50 years. It doesn’t work. The greedy become greedier, hoarding wealth to an unprecedented and disgusting degree, while the rest of us bicker and fight with one another for the tiniest of shrinking crumbs they left us to starve on.
I’m reminded of a cartoon I saw illustrating this very thing. Three people sitting at a table; one is rich, one is a typical blue collar male, and the other is a trans person. The rich person has a towering pile of cookies in front of them on the table; meanwhile the other two each have one cookie a piece. The rich person is pointing at the trans person while looking at the blue collar male and saying “Trans people are the problem. They took that cookie from you.” The greediest of the greedy have created a social class war in which they can continue pitting us against one another while they continue to take 95% of everything from us right out in broad daylight. Keep in mind - as a worker, those cookies the oligarchs hoard were made by YOU.
If you would like to see the specific sections I referenced in PL119-21 for yourself, here is the link to the government page of Public Law 119-21.
In the next part of this highlight, I will outline the programs that were cut or severely crippled in an attempt to balance the Republican budget of Detriment, Exclusion, and Irresponsibility outlined in PL119-21.
