Here is a bulleted summary of the provisions in the Ways and Means May 9 draft bill:

The bill provides that Section 15 of the Internal Revenue Code of 1986 shall not apply to any change in rate of tax by reason of any provision of, or amendment made by, this title (Title XI). This means the standard tax proration rules for rate changes within a tax year will not apply to changes enacted by this bill.

Subtitle A—Make American Workers and Families Thrive Again

Section 1100001: Extension of Modification of Rates. Extends the tax rate structure modified by prior law permanently by striking the expiration date.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100002: Extension of Increased Standard Deduction and Temporary Enhancement. Makes permanent the temporary increases to the standard deduction enacted by Public Law 115-97. It also temporarily increases the standard deduction amounts further by $2,000 (joint/surviving spouse), $1,500 (head of household), and $1,000 (other cases) for taxable years beginning after December 31, 2024, and before January 1, 2029.
- Effective Date: The permanent extension applies to taxable years beginning after December 31, 2025. The temporary additional increase applies to taxable years beginning after December 31, 2024.
Section 1100003: Termination of Deduction for Personal Exemptions. Permanently reduces the amount of the personal exemption to $0. Present law had already temporarily reduced it to $0 through 2025.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100004: Extension of Increased Child Tax Credit and Temporary Enhancement. Extends the increased child tax credit. Temporarily increases the maximum child tax credit to $2,500 for taxable years beginning after December 31, 2024, and before December 31, 2028. For taxable years beginning after December 31, 2028, the credit will be a permanent $2,000 indexed for inflation using a 2024 base year. Requires SSNs for the taxpayer, spouse, and qualifying child issued before the return due date and under specific Social Security Act provisions.
- Effective Date: Applies to taxable years beginning after December 31, 2024.
Section 1100005: Extension of Deduction for Qualified Business Income and Permanent Enhancement. Makes permanent the deduction for qualified business income (Section 199A). Increases the deduction percentage from 20 percent to 22 percent for various calculations. Modifies the limitations based on taxable income, replacing the existing phase-in with a two-step process involving W-2 wages/capital investment and a limitation phase-in amount equal to 75 percent of the excess taxable income over the threshold. Allows inclusion of qualified BDC interest dividends in the combined qualified business amount calculation. Modifies the inflation adjustment base year for the threshold amount to 2025.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100006: Extension of Increased Estate and Gift Tax Exemption Amounts and Permanent Enhancement. Permanently increases the unified estate and gift tax exemption to an inflation-indexed $15 million. The $15 million amount is indexed for inflation with a base year of 2025. The generation-skipping transfer tax exemption is also permanently increased to the same amount.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100007: Extension of Increased Alternative Minimum Tax Exemption and Phase-out Thresholds. Repeals the expiration of the increased AMT exemption amounts and phase-out thresholds enacted by Public Law 115-97.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100008: Extension of Limitation on Deduction for Qualified Residence Interest. Makes permanent the $750,000 limitation on acquisition indebtedness. Makes permanent the exclusion of interest on home equity indebtedness from the definition of qualified residence interest.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100009: Extension of Limitation on Casualty Loss Deduction. Makes permanent the temporary limitation on personal casualty losses in Section 165(h)(5), which generally allows deductions only for losses attributable to a Presidentially declared disaster.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100010: Termination of Miscellaneous Itemized Deduction. Makes permanent the temporary repeal of miscellaneous itemized deductions (those subject to the 2-percent floor) enacted by Public Law 115-97.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100011: Termination of Overall Limitation on Itemized Deductions. Permanently repeals the overall limitation on itemized deductions (the "Pease limitation"). This limitation was temporarily repealed by Public Law 115-97 through 2025.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100012: Termination of Qualified Bicycle Commuting Reimbursement Exclusion. Terminates the exclusion from gross income for qualified bicycle commuting reimbursements for taxable years beginning after December 31, 2025. This exclusion was temporarily repealed by Public Law 115-97 through 2025.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100013: Extension of Limitation on Exclusion and Deduction for Moving Expenses. Permanently repeals the deduction for moving expenses for individuals, except for members of the Armed Forces on active duty who move pursuant to a military order and incident to a permanent change of station. Permanently repeals the qualified moving expense reimbursement exclusion, except for the same military exception. These were temporarily repealed by Public Law 115-97 through 2025.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100014: Extension of Limitation on Wagering Losses. Makes permanent the clarification that "losses from wagering transactions" includes any deduction otherwise allowable incurred in carrying on any wagering transaction. This clarification was temporary under Public Law 115-97 through 2025.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100015: Extension of Increased Limitation on Contributions to ABLE Accounts and Permanent Enhancement. Makes permanent the ability for eligible designated beneficiaries who are employees to make additional contributions up to the lesser of compensation or the poverty line for a one-person household. Modifies the inflation adjustment for the maximum annual contribution limit (not including the employment-related contributions) to use a base year of 1996 instead of 1997.
- Effective Date: Generally applies to contributions made after December 31, 2025. The modified inflation adjustment applies to taxable years beginning after December 31, 2025.
Section 1100016: Extension of Savers Credit Allowed for ABLE Contributions. Makes permanent the temporary provision including ABLE account contributions made by the designated beneficiary as eligible contributions for the saver's credit.
- Effective Date: Applies to taxable years ending after December 31, 2025.
Section 1100017: Extension of Rollovers From Qualified Tuition Programs to ABLE Accounts Permitted. Makes permanent the temporary provision allowing nontaxable rollovers from 529 plans to ABLE accounts under certain conditions.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 1100018: Extension of Treatment of Certain Individuals Performing Services in the Sinai Peninsula and Enhancement to Include Additional Areas. Permanently treats qualified hazardous duty areas in the same manner as combat zones for certain tax benefits for members of the Armed Forces. Modifies the definition of qualified hazardous duty area to include Kenya, Mali, Burkina Faso, and Chad, in addition to the Sinai Peninsula, based on entitlement to hostile fire/imminent danger special pay.
- Effective Date: Takes effect on January 1, 2026.
Section 1100019: Extension of Exclusion from Gross Income of Student Loans Discharged on Account of Death or Disability. Restores the exclusion from gross income for the discharge of certain student loans and private education loans on account of a student's death or total and permanent disability. Requires inclusion of SSNs for the taxpayer and spouse on the return for the exclusion to apply. Treats the omission of a correct SSN as a mathematical or clerical error.
- Effective Date: Applies to discharges after December 31, 2025.

Subtitle B—Make Rural America and Main Street Grow Again

Section 111001: Extension of Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income. Lowers the preferential rates on GILTI and FDII by increasing the deduction for corporations for taxable years beginning after December 31, 2025. Increases the deduction for GILTI (and section 78 gross-up) from 37.5 percent to 50 percent. Increases the deduction for FDII from 21.875 percent to 37.5 percent.
- Effective Date: Applies to taxable years beginning after December 31, 2025.
Section 111002: Extension of Base Erosion Minimum Tax Amount. Repeals the special rules in Section 59A(b)(2), which would have increased the BEAT rate to 12.5 percent and reduced regular tax liability by all credits. Makes conforming amendments.
- Effective Date: Applies to taxable years beginning after December 31, 2025.

Subtitle C—Make America Win Again

Section 112001: Limiting Medicare Coverage of Certain Individuals. Adds a new section to Title XVIII of the Social Security Act. Limits entitlement or enrollment for Medicare benefits to individuals who are citizens or nationals of the United States, aliens lawfully admitted for permanent residence, or certain specified Cuban nationals. Includes a delayed application date and a review process for individuals currently entitled or enrolled as of the date of enactment.
- Effective Date: Specific effective date rules are outlined within the provision, including a one-year delay for individuals currently entitled or enrolled.
Section 112002: Modification of Administrative Exemptions Under the Tariff Act of 1930. Amends Section 321 of the Tariff Act of 1930. Restricts the "de minimis" privilege of duty-free entry for articles valued under $800 in cases where merchandise covered by a single order is forwarded in separate lots to gain the benefit. Prohibits the $800 privilege for articles subject to duties or restrictions under certain provisions of law (e.g., Subtitle A or B of title VII, Section 201 or 301 of the Trade Act of 1974, Section 232 of the Trade Expansion Act of 1962). Requires the 10-digit Harmonized Tariff Schedule classification to be provided for covered articles (originating from countries with Section 301 duties) to receive the $800 privilege. Establishes civil penalties for violations ($5,000 for the first, $10,000 for subsequent).
- Effective Date: Applies to articles entered, or withdrawn from warehouse for consumption, on or after the 30th day after the date of enactment.

Prepared with assistance from NotebookLM.