The “One Big Beautiful Bill Act” (OBBBA), signed into law on July 4, 2025, brings important changes for investment funds. The OBBBA also omits several anticipated provisions that would have adversely impacted investment funds. This alert highlights nine of the most relevant tax-related provisions and omissions and their practical effect on private equity and venture capital fund managers.
- Carried interest
- Pass-through entity taxes (PTET) and SALT deductions
- Qualified small business stock (QSBS)
- Interest deductibility
- Section 899 ‘revenge tax’
- Endowment tax
- Cuts to tax benefits for green-energy projects
- Miscellaneous itemized deductions for US individuals
- Downward attribution rules for controlled foreign corporations (CFCs)
The authors
Aalok Virmani
Stephanie Gentile
Jimmy Matteucci
Eileen Marshall
Hardy Zhou
