[Congressional Record Volume 171, Number 112 (Saturday, June 28, 2025)]
[Senate]
[Page S4024]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  SA 2608. Mr. LUJAN submitted an amendment intended to be proposed to 
amendment SA 2360 proposed by Mr. Thune (for Mr. Graham) to the bill 
H.R. 1, to provide for reconciliation pursuant to title II of H. Con. 
Res. 14; which was ordered to lie on the table; as follows:

       Strike section 70105 and insert the following:

     SEC. 70105. MODIFICATION OF 199A DEDUCTION.

       (a) Deduction Allowed for First $25,000 of Qualified 
     Business Income.--
       (1) In general.--Section 199A(b)(1) is amended to read as 
     follows:
       ``(1) In general.--The term `combined qualified business 
     income amount' means, with respect to any taxable year, an 
     amount equal to the lesser of--
       ``(A) the sum of the taxpayer's qualified business income 
     for each qualified trade or business carried on by the 
     taxpayer, or
       ``(B) $25,000.''.
       (2) Conforming amendments.--
       (A) Section 199A(a)(2) is amended by striking ``20 percent 
     of''.
       (B) Section 199A(b) is amended by striking paragraph (2).
       (b) Consolidated Taxpayer Level Adjusted Gross Income 
     Limitation.--Section 199A(b), as amended by subsection (a), 
     is amended--
       (1) by striking paragraph (3), and
       (2) by inserting after paragraph (1) the following new 
     paragraph:
       ``(2) Adjusted gross income limitation.--The combined 
     qualified business income of the taxpayer for the taxable 
     year shall be reduced (but not below zero) by so much of the 
     amount by which the adjusted gross income of the taxpayer 
     exceeds $200,000 ($400,000 in the case of a joint return).''.
       (c) Simplification With Respect to Loss Carryover.--Section 
     199(c) is amended by striking paragraph (2).
       (d) Other Conforming Amendments.--
       (1)(A) Section 199A(b) is amended by striking paragraph 
     (4).
       (B) Section 199A(g)(1)(B)(ii) is amended to read as 
     follows:
       ``(ii) W-2 wages.--For purposes of this subparagraph--

       ``(I) In general.--The term `W-2 wages' means, with respect 
     to any person for any taxable year of such person, the 
     amounts described in paragraphs (3) and (8) of section 
     6051(a) paid by such person with respect to employment of 
     employees by such person during the calendar year ending 
     during such taxable year.
       ``(II) Must be properly allocable to domestic production 
     gross receipts.--The W-2 wages of the taxpayer shall not 
     include any amount which is not properly allocable to 
     domestic production gross receipts for purposes of paragraph 
     (3)(A).
       ``(III) Return requirement.--Such term shall not include 
     any amount which is not properly included in a return filed 
     with the Social Security Administration on or before the 60th 
     day after the due date (including extensions) for such 
     return.''.

       (C) Section 199A(f)(1) is amended--
       (i) by inserting ``and'' at the end of subparagraph (A)(i),
       (ii) by striking ``, and'' at the end of subparagraph 
     (A)(ii),
       (iii) by striking clause (iii),
       (iv) by striking ``For purposes of clause (iii)'' and all 
     that follows through ``For purposes of this subparagraph'' 
     and inserting ``For purposes of this subparagraph'', and
       (v) by striking subparagraph (B) and redesignating 
     subparagraph (C) as subparagraph (B).
       (2)(A) Section 199A(b) is amended by striking paragraph 
     (5).
       (B) Section 199A(g)(5) is amended by adding at the end the 
     following new subparagraph:
       ``(F) Acquisitions, dispositions, and short taxable 
     years.--The Secretary shall provide for the application of 
     this subsection in cases of a short taxable year or where the 
     taxpayer acquires, or disposes of, the major portion of a 
     trade or business or the major portion of a separate unit of 
     a trade or business during the taxable year.''.
       (3) Section 199A(b) is amended by striking paragraph (6).
       (4)(A) Section 199A(b) is amended by redesignating 
     paragraph (7) as paragraph (3).
       (B) Section 199A(b)(3) (as so redesignated) is amended by 
     striking ``under paragraph (2)'' and inserting ``under 
     paragraph (1)(A)''.
       (5) Section 199A(d) is amended to read as follows:
       ``(d) Qualified Trade or Business.--For purposes of this 
     section, the term `qualified trade or business' means any 
     trade or business other than the trade or business of 
     performing services as an employee.''.
       (6) Section 199A(e) is amended to read as follows:
       ``(e) Taxable Income Defined.--For purposes of this 
     section, except as otherwise provided in subsection 
     (g)(2)(B), taxable income shall be computed without regard to 
     any deduction allowable under this section.''.
       (e) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2025.
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