II
119THCONGRESS
1
STSESSION S. 1121
To amend the Internal Revenue Code of 1986 to increase the adjusted
gross income limitation for above-the-line deduction of expenses of per-
forming artist employees, and for other purposes.
IN THE SENATE OF THE UNITED STATES
MARCH25, 2025
Mr. W
ARNER(for himself and Mr. TILLIS) introduced the following bill; which
was read twice and referred to the Committee on Finance
A BILL
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.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE. 3
This Act may be cited as the ‘‘Performing Artist Tax 4
Parity Act of 2025’’. 5
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SEC. 2. ABOVE-THE-LINE DEDUCTION OF EXPENSES OF 1
PERFORMING ARTISTS. 2
(a) I
NGENERAL.—Section 62(a)(2)(B) of the Inter-3
nal Revenue Code of 1986 is amended— 4
(1) by striking ‘‘
PERFORMING ARTISTS .—The 5
deductions’’ and inserting the following: ‘‘
PER-6
FORMING ARTISTS.— 7
‘‘(i) I
N GENERAL.—The deductions’’, 8
and 9
(2) by adding at the end the following new 10
clauses: 11
‘‘(ii) P
HASEOUT.—The amount of ex-12
penses taken into account under clause (i) 13
shall be reduced (but not below zero) by 10 14
percentage points for each $2,000 ($4,000 15
in the case of a joint return), or fraction 16
thereof, by which the taxpayer’s gross in-17
come for the taxable year exceeds 18
$100,000 (twice such amount in the case 19
of a joint return). 20
‘‘(iii) C
OST-OF-LIVING ADJUST -21
MENT.—In the case of any taxable year be-22
ginning in a calendar year after 2025, the 23
$100,000 amount under clause (ii) shall be 24
increased by an amount equal to— 25
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‘‘(I) such dollar amount, multi-1
plied by 2
‘‘(II) the cost-of-living adjust-3
ment determined under section 1(f)(3) 4
for the calendar year in which the tax-5
able year begins, determined by sub-6
stituting ‘calendar year 2024’ for ‘cal-7
endar year 2016’ in subparagraph 8
(A)(ii) thereof. 9
If any amount after adjustment under the 10
preceding sentence is not a multiple of 11
$1,000, such amount shall be rounded to 12
the nearest multiple of $1,000.’’. 13
(b) C
LARIFICATIONREGARDINGCOMMISSIONPAID 14
TOPERFORMINGARTIST’SMANAGER ORAGENT.—Sec-15
tion 62(a)(2)(B)(i) of the Internal Revenue Code of 1986, 16
as amended by subsection (a), is amended by inserting be-17
fore the period at the end the following: ‘‘, including any 18
commission paid to the performing artist’s manager or 19
agent’’. 20
(c) I
NCREASE INTHRESHOLD FOR DETERMINING 21
N
OMINALEMPLOYERS.—Section 62(b)(2) of the Internal 22
Revenue Code of 1986 is amended— 23
(1) by striking ‘‘An individual’’ and inserting 24
the following: 25
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‘‘(A) IN GENERAL.—An individual’’, 1
(2) by striking ‘‘$200’’ and inserting ‘‘$500’’, 2
and 3
(3) by adding at the end the following new sub-4
paragraph: 5
‘‘(B) C
OST-OF-LIVING ADJUSTMENT .—In 6
the case of any taxable year beginning in a cal-7
endar year after 2025, the $500 amount under 8
subparagraph (A) shall be increased by an 9
amount equal to— 10
‘‘(i) such dollar amount, multiplied by 11
‘‘(ii) the cost-of-living adjustment de-12
termined under section 1(f)(3) for the cal-13
endar year in which the taxable year be-14
gins, determined by substituting ‘calendar 15
year 2024’ for ‘calendar year 2016’ in sub-16
paragraph (A)(ii) thereof. 17
If any amount after adjustment under the pre-18
ceding sentence is not a multiple of $50, such 19
amount shall be rounded to the nearest multiple 20
of $50.’’. 21
(d) T
ECHNICAL ANDCONFORMINGAMENDMENTS.— 22
(1) Section 62(a)(2)(B)(i) of the Internal Rev-23
enue Code of 1986, as amended by the preceding 24
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provisions of this Act, is amended by striking ‘‘by 1
him’’ and inserting ‘‘by the performing artist’’. 2
(2) Section 62(b)(1) of such Code is amended 3
by inserting ‘‘and’’ at the end of subparagraph (A), 4
by striking ‘‘, and’’ at the end of subparagraph (B) 5
and inserting a period, and by striking subparagraph 6
(C). 7
(e) E
FFECTIVEDATE.—The amendments made by 8
this section shall apply to taxable years beginning after 9
December 31, 2024. 10
Æ
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