Overview

Title

To amend the Internal Revenue Code of 1986 to increase the adjusted gross income limitation for above-the-line deduction of expenses of performing artist employees, and for other purposes.

ELI5 AI

This bill helps actors and musicians save money on taxes by allowing them to write off more work expenses. The rules are a bit tricky, especially for artists who earn a lot, but the changes mean they can keep more money to help pay for things like agent fees starting in 2025.

Summary AI

S. 1121, titled the "Performing Artist Tax Parity Act of 2025," proposes an amendment to the Internal Revenue Code of 1986. The bill seeks to increase the income threshold at which performing artists can claim deductions for work-related expenses, introducing a phaseout of these deductions for incomes above $100,000, with adjustments for inflation over time. It clarifies that commissions paid to managers or agents can be deducted and raises the minimum earning amount for nominal employers to be considered, including provisions for cost-of-living adjustments. The changes are intended to apply to tax years starting after December 31, 2024.

Published

2025-03-25
Congress: 119
Session: 1
Chamber: SENATE
Status: Introduced in Senate
Date: 2025-03-25
Package ID: BILLS-119s1121is

Bill Statistics

Size

Sections:
2
Words:
869
Pages:
5
Sentences:
14

Language

Nouns: 212
Verbs: 78
Adjectives: 34
Adverbs: 5
Numbers: 46
Entities: 63

Complexity

Average Token Length:
3.90
Average Sentence Length:
62.07
Token Entropy:
4.75
Readability (ARI):
31.11

AnalysisAI

General Summary of the Bill

The proposed legislation, titled the "Performing Artist Tax Parity Act of 2025," seeks to amend the Internal Revenue Code of 1986. The primary aim is to increase the adjusted gross income limitation for the above-the-line deduction of expenses incurred by performing artist employees. The bill outlines several modifications to the existing tax code, including a phaseout of deductions for higher income levels, allowance for commissions paid to managers or agents, and an increase in the income threshold for what constitutes nominal employers. These changes are to be implemented for taxable years beginning after December 31, 2024.

Summary of Significant Issues

One major concern involves the complexity introduced by the phaseout of deductions in Section 2. For taxpayers with an income exceeding $100,000, the bill mandates a reduction of deductions by 10 percentage points for every $2,000 increment. This could complicate calculations, adding a layer of difficulty for performing artists in determining their entitled deductions.

Additionally, the use of specific income thresholds and the introduction of cost-of-living adjustments may lead to further intricacies in tax calculations, possibly creating unnecessary burdens for taxpayers. This complexity is compounded by changes to the nominal employers' threshold and the technical amendments made to the language of the tax code, which requires meticulous attention to ensure proper application.

Impact on the Public Broadly

For the general public, the bill will primarily affect taxpayers who are performing artists. The proposed adjustments aim to better align tax deductions with the economic realities faced by individuals in this profession. While the broader public might not experience direct effects, the bill highlights ongoing efforts to tailor the tax code to various sectors, reflecting sensitivity to the unique occupational expenses incurred by performing artists.

Impact on Specific Stakeholders

Performing Artists: The bill presents both potential advantages and challenges for performing artists. The increase in adjusted gross income limitation could provide relief to many within the sector, particularly those who incur substantial expenses related to their profession. However, the intricate rules surrounding deduction phaseouts might cause confusion, thereby necessitating careful income and deduction planning.

Accountants and Tax Preparers: These stakeholders may experience increased demand for their services as performing artists navigate the complexities introduced by the bill. Understanding new thresholds and accurately applying cost-of-living adjustments will require skill and precision.

Tax Authorities and Policymakers: The need for clear guidelines and communication will be crucial to ensure that performing artists correctly understand and apply these changes. This could lead to additional administrative burdens but also provides an opportunity to enhance tax code clarity and accessibility.

In conclusion, while the "Performing Artist Tax Parity Act of 2025" seeks to address disparities in tax treatment for performing artists, it introduces a range of complexities. The bill's impact largely depends on its implementation and the capacity of taxpayers and their advisors to adapt to the new provisions.

Financial Assessment

The "Performing Artist Tax Parity Act of 2025" focuses on changing the financial landscape for performing artists by amending how deductions related to their professional expenses are calculated and applied. These changes are primarily encapsulated in financial references throughout Section 2 of the bill.

Adjusted Gross Income Limitation and Phaseout

A significant financial aspect of this bill is the modification of the adjusted gross income limitation for performing artists. The bill specifies a phaseout mechanism for deductions: any deduction amount will be reduced by 10 percentage points for every $2,000 (or $4,000 in the case of joint returns) that a taxpayer's income exceeds $100,000 (or $200,000 for joint returns). This change impacts individuals with higher incomes, as it introduces an element of complexity into determining the correct deduction amounts. This complexity, identified as an issue, may lead to challenges for taxpayers in accurately calculating and applying these deductions in their tax filings.

Cost-of-Living Adjustments

The bill includes cost-of-living adjustments to ensure that the $100,000 income threshold reflects economic changes over time. Beginning in 2025, this threshold will be subject to annual increases based on inflation. These adjustments could further complicate tax planning for performing artists, as taxpayers will need to be aware of changing thresholds and calculate their deductions accordingly, possibly resulting in increased reliance on professional tax preparation services.

Inclusion of Manager or Agent Commissions

The legislation clarifies that performing artists can include commissions paid to managers or agents as part of their deductible expenses. This change expands the scope of deductible expenses and may provide some financial relief by allowing more comprehensive deduction claims. However, it adds another layer that artists must navigate to determine their allowable deductions accurately.

Increase in Threshold for Nominal Employers

Another financial change is the increase in the earnings threshold for determining what constitutes a nominal employer, moving from $200 to $500. This threshold will also be subject to cost-of-living adjustments. While this seems like a straightforward increase, taxpayers and their accountants must stay informed about these changes to ensure compliance. The increase, although beneficial, might not be immediately apparent to everyone, emphasizing the need for awareness and understanding of the updated thresholds.

Effective Dates and Planning

Finally, all these amendments are set to apply to taxable years beginning after December 31, 2024. This delayed effective date requires performing artists and accountants to plan ahead and make any necessary adjustments to their tax planning strategies to adapt to these changes. This transition period is crucial for preventing oversights and ensuring that artists maximize their potential deductions under the new regulations.

Overall, while the bill aims to provide tax relief to performing artists by increasing the deduction thresholds and allowing additional eligible deductions, the complexity of its financial provisions may lead to unintended confusion and increased administrative burdens for taxpayers and their advisors.

Issues

  • The complexity introduced by the phaseout of deductions in Section 2, which requires a 10 percentage point reduction in deductions for income exceeding $100,000, adds a layer of difficulty for taxpayers in calculating their benefits. This could lead to confusion and errors in tax filings.

  • The use of specific thresholds and cost-of-living adjustments in Section 2 could lead to unnecessary complexity in tax calculations, potentially resulting in extra burdens for performing artists and their accountants.

  • The adjustments to the nominal employers' threshold, as specified in Section 2, require awareness of these changes by taxpayers and accountants, as the increase from $200 to $500 might not be intuitive.

  • The technical and conforming amendments in Section 2 involve intricate changes to the wording, such as the change from 'by him' to 'by the performing artist,' which could be seen as unnecessarily complex and requiring careful interpretation to avoid misapplications.

  • The effective date in Section 2, set to apply changes to taxable years beginning after December 31, 2024, may require adjustments from taxpayers, adding potential for oversight and the need for future planning.

Sections

Sections are presented as they are annotated in the original legislative text. Any missing headers, numbers, or non-consecutive order is due to the original text.

1. Short title Read Opens in new tab

Summary AI

The first section of the act states that it will be officially known as the "Performing Artist Tax Parity Act of 2025."

2. Above-the-line deduction of expenses of performing artists Read Opens in new tab

Summary AI

The bill amends the tax code to adjust deductions for performing artists by creating a phaseout for those with higher incomes, allowing commissions paid to a manager or agent to be included as deductible expenses, and increasing the income threshold for determining nominal employers, with cost-of-living adjustments to take place after 2025. These changes will apply to taxable years beginning after December 31, 2024.

Money References

  • In general.—Section 62(a)(2)(B) of the Internal Revenue Code of 1986 is amended— (1) by striking “performing artists.—The deductions” and inserting the following: “performing artists.— “(i) IN GENERAL.—The deductions”, and (2) by adding at the end the following new clauses: “(ii) PHASEOUT.—The amount of expenses taken into account under clause (i) shall be reduced (but not below zero) by 10 percentage points for each $2,000 ($4,000 in the case of a joint return), or fraction thereof, by which the taxpayer’s gross income for the taxable year exceeds $100,000 (twice such amount in the case of a joint return).
  • “(iii) COST-OF-LIVING ADJUSTMENT.—In the case of any taxable year beginning in a calendar year after 2025, the $100,000 amount under clause (ii) shall be increased by an amount equal to— “(I) such dollar amount, multiplied by “(II) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting ‘calendar year 2024’ for ‘calendar year 2016’ in subparagraph (A)(ii) thereof.
  • If any amount after adjustment under the preceding sentence is not a multiple of $1,000, such amount shall be rounded to the nearest multiple of $1,000.”. (b) Clarification regarding commission paid to performing artist’s manager or agent.—Section 62(a)(2)(B)(i) of the Internal Revenue Code of 1986, as amended by subsection (a), is amended by inserting before the period at the end the following: “, including any commission paid to the performing artist’s manager or agent”. (c) Increase in threshold for determining nominal employers.—Section 62(b)(2) of the Internal Revenue Code of 1986 is amended— (1) by striking “An individual” and inserting the following: “(A) IN GENERAL.—An individual”, (2) by striking “$200” and inserting “$500”, and (3) by adding at the end the following new subparagraph: “(B) COST-OF-LIVING ADJUSTMENT.—In the case of any taxable year beginning in a calendar year after 2025, the $500 amount under subparagraph (A) shall be increased by an amount equal to— “(i) such dollar amount, multiplied by “(ii) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting ‘calendar year 2024’ for ‘calendar year 2016’ in subparagraph (A)(ii) thereof.
  • If any amount after adjustment under the preceding sentence is not a multiple of $50, such amount shall be rounded to the nearest multiple of $50.”. (d) Technical and conforming amendments.