For pass-through business owners, the most consequential change in the One Big Beautiful Bill Act (OBBBA) — signed into law as P.L. 119-21 on July 4, 2025 — is what didn't happen. The §199A QBI deduction did not sunset at the end of 2025. It is now permanent.
That single fact reshapes long-range planning for every sole proprietor, partner, and S-corp shareholder you advise. But OBBBA also did three other things to §199A that take effect for tax years beginning after December 31, 2025: it widened the phase-in ranges for the wage and property limits, it introduced a brand-new $400 minimum deduction for active small business owners, and it clarified that the new high-income itemized deduction cap doesn't bleed into the QBI calculation.
This guide walks through each change, the 2026 numbers from Rev. Proc. 2025-32, and the planning conversations to be having with clients now.
The Tax Cuts and Jobs Act (TCJA) of 2017 created §199A but built it as a temporary provision, scheduled to expire for tax years beginning after December 31, 2025. For seven tax seasons, every pass-through engagement carried an implicit asterisk: "this assumes the deduction still exists."
OBBBA removes the expiration date from IRC §199A(i) outright. There is no sunset, no extension cliff, no political pressure point looming at the end of 2027 or 2029. The 20% deduction is now part of the permanent law of the land, subject only to whatever Congress chooses to amend in the future.
What this enables in your planning conversations: entity structure decisions, retirement plan installations, and compensation strategies for S-corp shareholders can now be modeled on a 10- or 20-year horizon without back-end uncertainty. Previously, "what if §199A goes away" was a live risk in every multi-year projection.
OBBBA widens the income window in which the W-2 wage limit, qualified property (UBIA) limit, and SSTB exclusion phase in. Before OBBBA, the phase-in spanned $50,000 above the threshold for single filers and $100,000 for joint filers. Beginning with tax years after December 31, 2025, those ranges become $75,000 and $150,000 respectively, both indexed annually for inflation.
Per IRS Rev. Proc. 2025-32, the 2026 phase-in thresholds are:
| Filing Status | Below Threshold (Full Deduction) | Phase-In Range | Above (Full Limits Apply) |
|---|---|---|---|
| Married Filing Jointly | Under $403,500 | $403,500 – $553,500 | Over $553,500 |
| Single / Head of Household | ~Under $201,750 | ~$201,750 – $276,750 | ~Over $276,750 |
The single-filer thresholds shown above are derived figures — Rev. Proc. 2025-32 confirms the MFJ numbers and the $75,000/$150,000 range widths; the single thresholds will be set by Treasury in the standard annual inflation announcement. Verify against the final 2026 numbers before relying on them in a return.
Within the phase-in range, two things happen depending on the type of business:
A wider window means more taxable income can fall inside the partial-benefit zone. Owners who would have lost the deduction entirely under the old narrower range may now retain a portion. Practically, this is most impactful for SSTB owners (law, health, accounting, consulting, financial services) and for non-SSTB owners with limited W-2 wages whose deductions would have been heavily curtailed by the wage limitation.
Beginning in 2026, OBBBA establishes a floor: a taxpayer with at least $1,000 of aggregate qualified business income from one or more active trades or businesses gets a minimum QBI deduction of $400, regardless of what the normal calculation produces. Both the $1,000 threshold and the $400 floor are indexed for inflation after 2026.
The mechanics:
For a side-hustle LLC owner generating modest QBI, the floor delivers a small but real benefit they would have lost under the standard 20% calculation. For a W-2 employee with a $2,500 freelance side income, $400 off taxable income at the 24% bracket is $96 in actual federal tax savings — a small win but worth claiming.
Material participation matters: a passive investor in a pass-through doesn't qualify for the $400 minimum even if their share of QBI exceeds $1,000. The active-participation requirement under §469 has its own seven-test framework — most operating owners pass it, most pure investors don't.
Several things you might expect to have shifted, did not:
OBBBA introduces a new overall itemized deduction limitation for high-income taxpayers starting in 2026 (effectively capping the value of itemized deductions at 35% for the top bracket). The §199A statute as amended explicitly states that taxable income for purposes of the QBI calculation is determined without regard to that new limit.
Practically: a high-income client subject to the new itemized cap doesn't see their QBI deduction shrink as a side effect. The two limitations are independent. This was a clarifying choice by Congress that prevents a stacking penalty.
Any tax plan built with a 2026-onward "what if §199A is gone" scenario can be retired. Re-run long-range models with the deduction baked in permanently. For clients considering S-corp elections, equipment purchases timed around QBI, or installation of qualified retirement plans, the math may now favor different choices than it did under the sunset assumption.
SSTB owners with 2026 taxable income that would have been just above the old $494,600 MFJ ceiling — but is below the new $553,500 ceiling — now retain at least a partial deduction they would have lost completely. For a married SSTB owner at $520,000 of taxable income, this is a meaningful shift; under the prior law, the deduction was zero; under OBBBA, a phase-in calculation applies.
The W-2 wage limit's relevance has not diminished — for high-income clients, ensuring adequate W-2 wages still drives the deduction's size. But the wider phase-in window means clients who were previously above the lower threshold but with thin W-2 wages may now sit further into the phase-in zone, where the limit applies only partially. Re-evaluate the wage/distribution split each year against the new ranges.
For clients with a small active side business or a startup year with modest QBI, document material participation contemporaneously so the $400 floor is defensible. The participation test under §469 requires evidence — calendars, time logs, contemporaneous records — that the IRS can demand on examination.
With wider phase-in ranges, the math on whether to aggregate related pass-throughs changes. Aggregating may help a non-SSTB meet the W-2 wage / UBIA test more easily; but if any aggregated business is an SSTB, the entire group is treated as one. Re-run aggregation elections against 2026 thresholds before filing.
The updated QBI Deduction Calculator handles the new $400 minimum floor, expanded phase-in ranges, SSTB classification, and W-2 wage / UBIA limits — for both 2025 and 2026 tax years.
OBBBA's §199A changes don't rewrite the deduction so much as deepen its reach. The headline is permanence — the implicit asterisk in seven years of pass-through planning is now gone. The expanded phase-in ranges quietly let more SSTB and W-2-limited owners retain a partial deduction. The $400 minimum is small in absolute terms but meaningful for hundreds of thousands of side-business owners who would otherwise get nothing.
None of this is automatic for clients. Material participation must be documented. Aggregation elections must be made. Phase-in math must be run against the new ranges. The advisors who add the most value in 2026 are the ones who proactively walk every pass-through client through what changed — before the return is on the desk in March.