The newly enacted One Big Beautiful Bill Act^[i] (OBBBA) brings sweeping changes to the U.S. tax code, with far-reaching implications for ultra-high-net-worth individuals and multi-generational families. From expanded estate and gift tax exemptions to enhanced investment incentives and charitable planning tools, the OBBBA introduces new opportunities—and new complexities—for strategic wealth management. The following is a summary of key provisions that may be most relevant.

Extension of Individual Provisions^[ii]

The Tax Cuts and Jobs Act of 2017 (TCJA) laid out several provisions that were set to expire at the end of 2025. The One Big Beautiful Bill Act (OBBBA) has made many of these permanent, including:

• The current seven federal tax bracket structure for individual taxpayers: 10%, 12%, 22%, 24%, 32%, 35%, and 37%; for trusts and estates, a continuation of the compressed four-bracket structure: 10%, 24%, 35%, and 37%; a continuation of the current capital gain rate structure: 0%, 15%, and 20%; and a continuation of the 3.8% net investment income tax for those over prescribed income thresholds.

• Elimination of almost all miscellaneous itemized deductions (e.g., investment advisory fees, certain attorneys’ fees, safe deposit box rental, etc.).

• Increased Alternative Minimum Tax (AMT) exemption and threshold amounts.

• $750,000 principal limit on mortgage debt eligible for mortgage interest deduction (deduction limited to interest on mortgage proceeds used to acquire a qualified residence and certain refinances of such mortgages; interest on mortgage loans not used to buy, build, or substantially improve a qualified residence remain non-deductible).

Standard Deduction^[iii]

Higher amounts for the standard deduction set forth by the TCJA were also set to expire at the end of 2025. The Act increases the amount of standard deduction starting in 2025 and that amount is set to be adjusted annually for inflation. The new amount of the standard deduction in 2025 is $31,500 for joint filers, $23,625 for heads of households, and $15,750 for single and married taxpayers filing separately.

State and Local Tax (SALT) Deduction^[iv]

The Act increases the SALT deduction cap to $40,000 for 2025, with a 1% increase in the cap each year through 2029 before returning to the $10,000 limit in 2030. The cap is reduced by 30% of the amount that a taxpayer’s modified adjusted gross income (MAGI) exceeds $500,000 in 2025, not to be reduced below $10,000. In other words, taxpayers with MAGI of $600,000 or more in 2025 will be limited to the $10,000 SALT deduction. The $500,000 AGI threshold will increase by 1% annually through 2029.

Child Tax Credit^[v]

The amount of the child tax credit has been permanently increased to $2,200 for each qualifying child under age 17 beginning in 2025, with annual adjustments for inflation.

Estate and Gift Tax Exemption^[vi]

The basic exclusion amount for estate and gift taxes and the exemption amount for generation-skipping transfer (GST) tax purposes increases to $15 million in 2026 and adjusts for inflation each year thereafter.

NEW INDIVIDUAL PROVISIONS

Qualified Tip Income Deduction^[vii]

The Act does not provide an exclusion from tax on tips, but rather a deduction from income for cash tips reported to their employer for payroll tax withholdings. Taxpayers are not required to itemize deductions to claim the deduction, but a social security number is required to claim the deduction. The deduction is capped at $25,000 and begins to phase out when the taxpayer’s MAGI income exceeds $150,000 ($300,000 for joint filers).

Overtime Pay Deduction^[viii]

Under the OBBBA, taxpayers can claim a deduction for overtime pay received. Similar to the deduction for tip income, taxpayers do not have to itemize deductions to claim the deduction but are required to provide a social security number. The deduction is capped at $12,500 for individuals ($25,000 married filing jointly) and begins to phase out when the taxpayer’s MAGI exceeds $150,000 ($300,000 for joint filers).

Senior Deduction^[ix]

A $6,000 personal exemption deduction is provided for seniors age 65 or older after 2024 and before 2029. This deduction is phased out for individuals whose modified adjusted gross income exceeds $75,000 ($150,000 for joint filers). The deduction is completely phased out at $175,000 ($250,000 for joint filers).

Itemized Deduction Limitation^[x]

Beginning in 2026, the Act limits the value of all itemized deductions (SALT or otherwise), in most instances, to 35 cents on the dollar for taxpayers in the top 37% bracket.

Automobile Loan Interest^[xi]

The Act includes a deduction of up to $10,000 for interest paid on an automobile loan in 2025 through 2028 for a new vehicle purchased after 2024. The deduction is only applicable to vehicles whose final assembly took place in the US. The deduction is available for both itemizers and non-itemizers. Note: the deduction begins to phase out for individuals whose annual income exceeds $100,000 ($200,000 married filing jointly) and is completely phased out for those with MAGI of $150,000 or more ($250,000 or more for joint filers).

529 Plans^[xii]

The OBBBA expands 529 programs to include elementary and secondary school tuition, materials and certain other educational expenses incurred for classes outside of the home including a K-12 withdrawal limit from $10,000 to $20,000 per year and K-12 “qualified expenses” definition to include non-tuition costs such as curriculum materials, fees for standardized testing, dual-enrollment fees for college courses taken in high school, tutoring, etc.

Federal Tax Credit for Contributions to Scholarship-Granting Organizations^[xiii]

Beginning in 2027, taxpayers may claim a federal tax credit of up to $1,700 for donations to state-approved scholarship-granting organizations (federal tax credit reduced dollar for dollar to the extent scholarship contributions are claimed as a credit on any state income tax return).

Above-the-Line Charitable Deduction; 0.5% AGI Floor on Charitable Contributions^[xiv]

The Act established a Charitable Contribution Deduction for individuals who do not itemize. The deduction is up to $1,000 ($2,000 married filing joint) for non-itemizers. For itemizers, a new floor is introduced where deductions are only permitted for contributions exceeding 0.5% of your AGI. The deductions are applicable beginning in 2026. Cash contributions to public charities remain deductible in the year of payment (i.e., no carryover to future year) if equal to or less than 60% of the taxpayer’s MAGI.

BUSINESS PROVISIONS

Bonus Depreciation^[xv]

The OBBBA makes 100% “bonus” depreciation of certain business property permanent for property acquired after January 19, 2025 (40% “bonus” depreciation still applies to property acquired between January 1, 2025 and January 19, 2025).

Qualified Business Income Deduction^[xvi]

Under the Act, the qualified business income deduction is made permanent. The deduction remains equal to 20% of the taxpayer’s qualified business income. Additional changes expand qualification for the deduction.

Section 179 Immediate Expensing of Certain Depreciable Business Assets^[xvii]

Under Section 179, taxpayers are allowed to immediately deduct the cost of certain depreciable personal property used in a trade or business, subject to dollar limitations and phase outs. For 2025, most businesses can elect to immediately deduct up to $2.5 million on the purchase of certain depreciable personal property (dollar-for-dollar phase out occurs to the extent eligible property purchases exceed $4.0 million). Dollar limitation and phase out figures are indexed annually for inflation.

New 100% “Bonus” Depreciation Deduction for Certain Manufacturers^[xviii]

A new subsection (“(n)”) aimed at manufacturers has been added to Internal Revenue Code Section 168 that permits certain taxpayers to deduct 100% of the cost of certain “qualified production property.” In general, qualified production property means the portion of otherwise depreciable nonresidential real property that is used in manufacturing or producing tangible personal property. Construction of the property must begin after January 19, 2025 and before January 1, 2029 (property must be placed in service before January 1, 2031). Existing property that is purchased between January 19, 2025 and January 1, 2029 and that was not used in a qualified production activity between January 1, 2021 and May 12, 2025 may also qualify for this deduction. For manufacturers considering plant upgrades, additions, or relocations, please consult your tax advisor for further details on the subsection 168(n) deduction eligibility requirements (including limitations and recapture potential).

Qualified Opportunity Zone Investments^[xix]

Under the TCJA, an investor who sold assets and realized capital gain could elect to put those gains to work under a tax stimulus program designed to grow jobs and improve the local economy in lower-income communities (Opportunity Zones). To the extent an investor reinvests these capital gains in a Qualified Opportunity Zone Fund (QOF), TJCA allows the investor to defer recognition of those capital gains for income tax purposes until a future date (earlier than (1) date investor sells QOF or (2) Dec. 31, 2026). The Opportunity Zone regime created under the TCJA expires on December 31, 2026.

The OBBBA creates a new Opportunity Zone regime, which takes effect after December 31, 2026. Under this new regime, a taxpayer may, again, elect to reinvest capital gains in a QOF and defer recognizing these gains for up to five years; if the investor holds the QOF for five years, then when the deferred gain is recognized in that fifth year, the investor may reduce the gain recognized by 10% (by 30% if the deferred gain is reinvestments in qualified rural opportunity funds).

If an investor continues to hold a QOF for an additional five years (i.e., an investor holds a QOF for 10 or more years), then the investor does not recognize any gain when he or she sells or disposes of the QOF investment.

Qualified Small Business Stock Gain Exclusion^[xx]

Under current law, taxpayers may exclude all or a portion of gain realized on the sale of qualified small business stock (QSBS): stock of a C Corporation that satisfies distinct requirements regarding corporate asset values, business activity, and stock issuance (among other requirements). Depending on when the QSBS was acquired, the exclusion may apply to 100%, 75%, or 50% of gain recognized on the sale or disposition of the QSBS, subject to certain limitations (e.g., gain exclusion capped at the greater of $10 million or 10-times the taxpayer’s stock basis in the QSBS).

Under the OBBBA, for QSBS acquired after July 3, 2025, a taxpayer may exclude 50% of the gain realized on the sale of a QSBS if held for three years, 75% of the gain realized if the QSBS is held for four years, and 100% of the gain realized if the QSBS is held for five or more years, with the gain exclusion capped in all cases at the greater of (1) $15 million (rather than $10 million) or (2) 10-times stock basis. In addition, certain eligibility standards have been loosened that should expand QSBS eligibility (e.g., corporations with gross asset values of up to $75 million may be eligible for QSBS status under the OBBBA; under current law, QSBS status is limited to corporations with $50 million or less of gross asset value).

While QSBS status can be quite valuable, eligibility is nuanced and may involve considerable (i.e., years) of pre-sale planning, and its benefits (which are future in nature) must be compared with alternatives, which may be more valuable in current dollars. For families with closely held business interests that are potential acquisition candidates in the mid- to long-term, consult with your tax advisor to explore QSBS eligibility, benefits, and alternatives.

Information Reporting (1099) Threshold^[xxi]

Beginning in 2026, the threshold for having to issue information returns (i.e., 1099s) to the IRS (and vendors and contractors) increases from $600 to $2,000, which should reduce some tax compliance burden.

[i] One Big Beautiful Bill Act, Pub. L. No. 119-21 (2025).

[ii] Id. at Sections 70101, 70103, 70110, 70107, 70108, 70109, and 70110

[iii] Id. at Section 70102

[iv] Id. at Section 70120

[v] Id. at Section 70104

[vi] Id. at Section 70106

[vii] Id. at Section 70201

[viii] Id. at Section 70202

[ix] Id. at Section 70103

[x] Id. at Section 70111

[xi] Id. at Section 70203

[xii] Id. at Sections 70413 & 70414

[xiii] Id. at Section 70411

[xiv] Id. at Sections 70424 & 70425

[xv] Id. at Section 70301

[xvi] Id. at Section 70105

[xvii] Id. at Section 70306

[xviii] Id. at Section 70307

[xix] Id. at Section 70421

[xx] Id. at Section 70431

[xxi] Id. at Section 70433

This report has been prepared from sources and data believed to be reliable but not guaranteed to or by Synovus Trust Company, N.A. (STC). Opinions expressed are subject to change without notice. Synovus Trust Company, N.A. has prepared and presented this report for the sole usage of its clients as information and is neither an offer to sell nor a solicitation of an offer to buy any security.

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