| Introduction | 57 |
| Chapter Learning Objectives | 57 |
| Credit for Foreign Taxes Paid Modified | 57 |
| OBBBA Increases Foreign Taxes Paid Credit | 57 |
| Extension And Enhancement Of Deduction For Qualified Business Income | 58 |
| OBBBA Makes QBI Deduction Permanent, Extends Phase-In & Establishes New Deduction | 58 |
| New Minimum Deduction | 59 |
| Extension and Enhancement of Paid Family and Medical Leave Credit | 59 |
| OBBBA Makes PFML Credit Permanent, adds Insurance Premium Credit & Reduces Tenure Requirement | 59 |
| Exceptions from Limitations on Deduction for Business Meals | 59 |
| OBBBA Increases Meal Deduction for Restaurants, Caterers, Fishing Boats & Processers | 60 |
| Enhancement of Advanced Manufacturing Investment Credit | 60 |
| OBBBA Increases Advanced Manufacturing Investment Credit | 60 |
| Sourcing Certain Income from the Sale of Inventory Produced in the United States | 60 |
| OBBBA Allows 50 Percent of U.S. Produced Inventory to be Considered Foreign-Sourced | 60 |
| Modifications Related to Foreign Tax Credit Limitation | 61 |
| OBBBA Changes Foreign Tax Credit Limitations | 61 |
| Modification of Deduction for Foreign-Derived Deduction Eligible Income and Net CFC Tested Income | 61 |
| OBBBA Foreign-Derived Deduction Eligible Income and Net CFC Tested Income | 61 |
| Rules Related to Deemed Intangible Income | 62 |
| OBBBA Repeals Tax-Free Deemed Return on Foreign Investments | 62 |
| Extension and Modification of Base Erosion Minimum Tax Amount | 62 |
| OBBBA Increases the BEAT Rate to 10.5% | 62 |
| Coordination of Business Interest Limitation with Interest Capitalization Provisions | 62 |
| OBBBA Requires Application of Business Interest Limitation Before Interest Capitalization | 62 |
| Definition of Adjusted Taxable Income for Business Interest Limitation | 63 |
| OBBBA Amends ATI Definition Increasing Business Interest Expense Deduction | 63 |
| Permanent Extension of Look-Thru Rule for Related Controlled Foreign Corporations | 63 |
| OBBBA Extends CFC Look-Thru Rule | 63 |
| Enhancement of Employer-Provided Child Care Credit | 63 |
| OBBBA Increases Child Care Credit Amount and Percentage of Expenditures | 64 |
| Enhancement of the Dependent Care Assistance Program | 64 |
| OBBBA Increases Dependent Care Assistance | 64 |
| Modification of Tax on Investment Income of Private Colleges & Universities | 64 |
| OBBBA Imposes Higher Taxes on Some Private Colleges & Universities | 64 |
| Expanding application of tax on excess compensation within tax-exempt organizations | 65 |
| OBBBA Changes "Covered Employee" Definition Potentially Increasing Excise Tax | 65 |
| Permanent Renewal and Enhancement of Opportunity Zones | 65 |
| OBBBA Makes Opportunity Zones Program Permanent & Imposes Stricter Guidelines | 66 |
| Permanent Enhancement of Low-Income Housing Tax Credit | 67 |
| OBBBA Increases Low-Income Housing Tax Credits & Permits 100% Expensing | 67 |
| Permanent Extension of New Markets Tax Credit | 68 |
| OBBBA Permanently Extends New Markets Tax Credit | 68 |
| 1-Percent Floor on Deduction of Charitable Contributions made by Corporations | 68 |
| OBBBA Limits Corporate Charitable Deduction to Contributions over 1% of Taxable Income | 68 |
| Permanent Increase in Limitation on Cover Over of Tax on Distilled Spirits | 69 |
| OBBBA Increases Cover Over Payments to Puerto Rico & U.S. Virgin Islands | 69 |
| Adjustment of Charitable Deduction for Certain Expenses Incurred in Support of Native Alaskan Subsistence Whaling | 69 |
| OBBBA Increases Limit for Charitable Deduction for Whaling Captain Expenses | 69 |
| Increase in Threshold for Requiring Information Reporting with Respect to Certain Payees | 69 |
| OBBBA Raises Reporting Independent Contractor Threshold to $2,000 | 69 |
| Reduction of Transfer and Manufacturing Taxes for Certain Devices | 69 |
| OBBBA Eliminates Transfer & Manufacturing Tax on Specified Firearms | 69 |
| Restoration of Taxable REIT Subsidiary Asset Test | 70 |
| OBBBA Increases REIT's Asset Limit Held in Taxable REIT Subsidiary | 70 |
| Modifications to De Minimis Entry Privilege for Commercial Shipments | 70 |
| OBBBA & Executive Order Eliminate De Minimis Entry Privilege, Impose Violation Penalty | 70 |
| Modification and Extension of Limitation on Excess Business Losses of Noncorporate Taxpayers | 70 |
| OBBBA Reduces EBL Limitation & Makes Rule Permanent | 70 |
| Excessive Employee Remuneration from Controlled Group Members and Allocation of Deduction | 71 |
| OBBBA Broadens Controlled Group Definition & Aggregates Compensation for Deduction Limit | 71 |
| Extension and Modification of Qualified Transportation Fringe Benefits | 72 |
| OBBBA Eliminates Deductibility of Most Transportation Fringe Benefits | 72 |
| Summary | 72 |
| Chapter 5 Review | 73 |