S. 3459

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 3459 Introduced in Senate (IS)]

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119th CONGRESS
1st Session
S. 3459

To amend the Internal Revenue Code of 1986 to provide a payroll tax 
deduction for certain small businesses, and for other purposes.

_______________________________________________________________________

IN THE SENATE OF THE UNITED STATES

December 11, 2025

Mr. Ossoff (for himself and Mrs. Hyde-Smith) 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 provide a payroll tax 
deduction for certain small businesses, and for other purposes.

Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

This Act may be cited as the ``Support Small Business Growth Act of 
2025''.

SEC. 2. PAYROLL TAX DEDUCTION FOR SMALL BUSINESSES.

(a) In General.--Part VI of subchapter B of chapter 1 of the 
Internal Revenue Code of 1986 is amended by inserting after section 176 
the following new section:

``SEC. 177. PAYROLL DEDUCTION FOR QUALIFIED SMALL BUSINESSES.

``(a) In General.--In the case of a qualified small business, in 
addition to the deduction allowed by section 162(a)(1), there shall be 
allowed as a deduction an amount equal to the sum of the applicable 
amounts determined under subsection (b)(2) with respect to each full-
time employee of the employer which has been designated by such 
employer pursuant to subsection (b)(1).
``(b) Limitations; Applicable Amount.--
``(1) Designation of employees.--
``(A) In general.--For purposes of subsection (a), 
with respect to any taxable year, the full-time 
employees designated by the employer (at such time and 
in such manner as the Secretary may provide) shall--
``(i) not exceed the applicable maximum 
number of employees,
``(ii) only include those full-time 
employees with the lowest wages paid during 
such taxable year relative to all other full-
time employees of such employer, and
``(iii) not include any highly compensated 
employee.
``(B) Applicable maximum number.--For purposes of 
subparagraph (A), the applicable maximum number with 
respect to any qualified small business is--
``(i) 10, in the case of a taxable year 
beginning in 2026, 2027, 2028, 2029, or 2030,
``(ii) 8, in the case of a taxable year 
beginning in 2031,
``(iii) 6, in the case of a taxable year 
beginning in 2032,
``(iv) 4, in the case of a taxable year 
beginning in 2033, and
``(v) zero thereafter.
``(2) Applicable amount.--
``(A) In general.--For purposes of subsection (a), 
with respect to each full-time employee designated 
pursuant to paragraph (1), the applicable amount shall 
be an amount equal to the lesser of--
``(i) the applicable wage limitation, or
``(ii) 12 percent of the wages paid to such 
employee during the taxable year.
``(B) Applicable wage limitation.--For purposes of 
subparagraph (A), the applicable wage limitation is--
``(i) $8,000, with respect to the number of 
full-time employees designated pursuant to 
paragraph (1) which is equal to--
``(I) the applicable maximum number 
with respect to the qualified small 
business for the taxable year, reduced 
by
``(II) 2,
``(ii) $6,000, with respect to 1 additional 
such employee, if applicable, and
``(iii) $4,000, with respect to 1 
additional such employee, if applicable.
``(c) Qualified Small Business.--For purposes of this section, the 
term `qualified small business' means, with respect to a taxable year, 
a small business concern (as defined under section 3 of the Small 
Business Act) which--
``(1) as of the last date of such taxable year--
``(A) has not more than 15 full-time employees, and
``(B) meets the gross receipts test of section 
448(c), and
``(2) certifies to the Secretary, at such time and in such 
manner as the Secretary shall prescribe, that such concern 
meets the requirements of this subsection for the taxable year.
``(d) Definitions.--For purposes of this section--
``(1) Full-time employee.--The term `full-time employee' 
has the meaning given such term by section 4980H(c)(4).
``(2) Highly compensated employee.--The term `highly 
compensated employee' has the meaning given such term by 
section 414(q).
``(e) Termination.--This section shall not apply to taxable years 
beginning after December 31, 2033.''.
(b) Clerical Amendment.--The table of sections for part VI of 
subchapter B of chapter 1 of the Internal Revenue Code of 1986 is 
amended by inserting after the item relating to section 176 the 
following new item:

``Sec. 177. Payroll deduction for qualified small businesses.''.
(c) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 2025.
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