“One Big Beautiful Bill” Tax Provisions for Energy Marketers

July 6, 2025

The Republican-controlled Congress passed a multi-trillion-dollar reconciliation package, known as the One Big Beautiful Bill Act (H.R. 1) by a vote of 218-214 prior to the July 4th holiday. Representatives Thomas Massie (R-KY) and Brian Fitzpatrick (R-PA) opposed the bill along with all democrats. Earlier in the week, the Senate approved the bill 51-50, with Vice President J.D. Vance casting a tie-breaking vote in favor of passage. Sens. Susan Collins (R-ME), Rand Paul (R-KY), and Thom Tillis (R-NC) joined all Democrats in opposition to the bill. President Trump signed the legislation on July 4th.

The Energy Marketers of America (EMA) endorsed the One Big Beautiful Bill, which bolsters family-owned and privately held energy marketing companies. “By reinstating the vital pass-through deduction and full bonus depreciation, this bill enables small business energy marketers to keep delivering affordable, reliable motor and heating fuels to Americans,” stated EMA President Rob Underwood. EMA also joined other supporters in signing a letter backing the legislation.

What is Included in the One Big Beautiful Bill? Notable tax provisions for energy marketers include:

  • TCJA Extension – As with the House-passed bill, the legislation makes permanent or extends several expiring provisions from the 2017 Tax Cuts and Jobs Act (TCJA), including:
    • Individual Income Tax Rates: The bill makes permanent the individual income tax rates enacted by TCJA.
    • Standard Deduction: The bill makes permanent TCJA’s increase to the standard deduction and further temporarily increases the standard deduction for tax year 2025. The legislation also permanently reduces the deduction for personal exemptions and miscellaneous itemized deductions which were temporarily limited by TCJA.
    • Section 199A Pass-Through Deduction: The bill makes permanent the 20 percent Section 199A qualified business income deduction, among several other changes.
    • Bonus Depreciation: The legislation permanently restores 100 percent bonus depreciation, effective January 20, 2025, allowing businesses to immediately deduct 100 percent of the cost of certain short-term investments (e.g., equipment and machinery) from their taxable income in the first year rather than over fixed intervals.
    • Interest Deductibility: The bill restores the EBITDA (earnings before interest, taxes, depreciation, and amortization)-based limitation on the net business interest deduction effective December 31, 2024.
    • Alternative Minimum Tax: The bill makes permanent TCJA’s increase in the alternative minimum tax (AMT) exemption but reverts the exemption phaseout thresholds to 2018 levels. The reversion may result in additional individuals being subject to the AMT and therefore excluded from claiming the SALT deduction.
    • Estate and Gift Tax: The bill permanently increases the estate and gift tax exemption level to $15 million, beginning after December 31, 2025, and indexes the increase to inflation.
    • Special Depreciation for Manufacturing Facilities: The legislation includes a new 100 percent bonus depreciation allowance for certain manufacturing, production, or refining facilities.
    • EV Tax Credits: The legislation terminates the Section 25E Previously Owned Clean Vehicle Credit, the Section 30D Clean Vehicles Credit, and the Section 45W Commercial Clean Vehicle Credit for vehicles acquired after September 30, 2025. The bill also terminates the Section 30C Alternative Fuel Vehicle Refueling Property credit with respect to property placed in service after June 30, 2026. Unfortunately, the legislation doesn’t include a fee on EVs to pay their fair share into the Highway Trust Fund (HTF).
    • Clean Fuel Production Credit (Section 45Z): The legislation extends the Section 45Z Clean Fuel Production Credit until December 31, 2029, and ensures tax parity for fuel marketers by eliminating the special rate for Sustainable Aviation Fuel – providing the same credit value as for other eligible transportation fuels, with a maximum value of $1.00. Additionally, it prohibits claiming the credit for fuels derived from feedstocks produced or grown outside the US, Mexico, or Canada, effective after December 31, 2025.
    • State & Local Tax (SALT) Deduction Cap: The legislation proposes to increase the current cap on the state and local tax (SALT) deduction to $40,000 through 2029 (with modest annual increases in the deduction between 2026 and 2029). The legislation would revert the SALT deduction cap to $10,000 (consistent with current law) starting after 2029.
    • Home Efficiency Tax Credit (25C): Unfortunately, the bill terminates the Home Efficiency Tax Credit (25C) after December 31, 2025. This credit currently provides 30% of the cost of installation for qualified home efficiency improvements including oil-fired furnaces and boilers which are eligible for up to $600 if they meet 2021 ENERGY STAR® specifications and are designed for use with high blends of renewable fuels.
    • Clean Hydrogen Production Credit (Section 45V): The bill terminates the Section 45V Credit for Clean Hydrogen Production for facilitates beginning construction after December 31, 2027.
    • Residential Clean Energy Credits: The legislation terminates the Section 25D Residential Clean Energy Credit 180 days after enactment. The legislation also terminates the Section 45L New Energy Efficient Home Credit 1 year after enactment.
    • Greenhouse Gas Emissions Reduction Fund (GGRF): Many of the IRA programs that were targeted for repeal in the original bill now will only have their unobligated funds rescinded. The GGRF, however, will be repealed completely.

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