
Most of the tax changes within the bill make the statutes first introduced in the TCJA from 2017 permanent. These were otherwise due to expire at the end of 2025.
Some of the statutes which are now permanent include:
Further statutes within the bill build on the changes discussed above. These include:
The new ‘Remittance Transfer Excise Tax’ was first proposed at 5% but has been passed as a 1% transaction-based excise tax on money transfers sent out from the US after 31 December 2025.
The tax is imposed regardless of one’s legal status in the US, so applies to US citizens, green card holders, individuals working in the US, and even tourists.
The new tax has been substantially mellowed since its initial proposal and will only now apply to transfers via cash, money order, cashier’s check or other similar physical instruments. It does not apply to credit or debit card transactions where the card is issued in the US, nor transfers originating from accounts held in or by most commercial financial institutions, which includes a broker or dealer in securities, investment and commercial banks.
The tax will be collected at the time of the transfer by the transfer provider and will therefore not be reported via a personal tax return. It will also not be creditable against Income Tax (as it had originally been intended).
Given the exclusions mentioned above, we do not expect this new excise tax to have a significant, if any, impact on US individuals residing outside the US.
These are new accounts for children under 18 with a Social Security Number. They are tax-favoured and will generally be treated in the same way as an Individual Retirement Account (IRA) for tax purposes. All newborn children born between 2025 and 2028 will receive a $1,000 deposit to fund the account. Contributions to these accounts are limited to $5,000, and investments are limited to various mutual and tracker funds.
Although no details have yet been shared, the Big Beautiful Bill Act has appropriated funds for a task force to investigate how to terminate the IRS Direct File Program.
Residence-based taxation
Despite being a talking point throughout President Trump’s 2024 election campaign, the act does not make any reference to changes to the citizenship-based taxation for Americans. Trump has spoken of his wish to abolish worldwide taxation of US citizens living abroad in favour of a residence-based tax system, saying the US citizenship-based system is outdated and unfair. Despite this, and support from some Democrats, such a change is yet to be seen.
Expatriation
Significant tax changes often lead to queries regarding expatriation. It is worth noting that there was no mention of updates to the expatriation process at this time.
If you’re concerned about how these changes might impact your tax affairs, please fill out the form below. One of our experts will be in touch to discuss your requirements and how we can help.