Sec. 110005. Extension of deduction for qualified business income and permanent enhancement
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Section 199A is amended by striking subsection (i). Subsections (a)(2), (b)(1)(B), and (b)(2)(A) of section 199A are each amended by striking 20 percent and inserting 23 percent . Section 199A(b)(3) is amended to read as follows: In the case of any taxpayer whose taxable income for the taxable year does not exceed the threshold amount— paragraph
(2)shall be applied without regard to subparagraph (B), and a specified service trade or business shall not fail to be treated as a qualified trade or business solely by reason of subsection (d)(1)(A). In the case of any taxpayer whose taxable income for the taxable year exceeds the threshold amount, the sum described in paragraph (1)(A) (determined without regard to this subparagraph) shall instead be an amount (if greater) equal to the excess (if any) of— the sum described in paragraph (1)(A) (determined by applying the rules of clauses
(i)and
(ii)of subparagraph (A)), over the limitation phase-in amount. For purposes of subparagraph (B), the limitation phase-in amount shall be an amount equal to 75 percent of the excess (if any) of— the taxable income of the taxpayer for the taxable year, over the threshold amount. . Section 199A(d) is amended by striking paragraph (3). Subsections (b)(1)(B) and (c)(1) of section 199A are each amended by inserting , qualified BDC interest dividends, after qualified REIT dividends . Section 199A(e) is amended by adding at the end the following new paragraph: The term qualified BDC interest dividend means any dividend from an electing business development company received during the taxable year which is attributable to net interest income of such company which is properly allocable to a qualified trade or business of such company. For purposes of this paragraph, the term electing business development company means a business development company (as defined in section 2(a) of the Investment Company Act of 1940) which has an election in effect under section 851 to be treated as a regulated investment company. . Section 199A(e)(2)(B) is amended— by striking 2018 and inserting 2025 , and in clause (ii), by striking , determined by substituting . calendar year 2017 for calendar year 2016 in subparagraph (A)(ii) thereof The amendments made by this section shall apply to taxable years beginning after December 31, 2025.