Tax break for leveraged corporations quietly restored in short bill
H.R. 8101 — Ensuring Better Interest Treatment and Deductibility Act (EBITDA) · Filed by Ron Estes (R-KS) · 23 cosponsors · Introduced Mar 26, 2026 · Referred to committee
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What it does
This bill repeals a recent modification to how 'adjusted taxable income' is calculated for the business interest deduction limit under Section 163(j) of the tax code. By striking clause (vi) and restoring an earlier definition, the bill effectively allows businesses to add back depreciation and amortization when calculating how much interest they can deduct — returning to an EBITDA-based standard rather than an EBIT-based one. Businesses, particularly capital-intensive ones with large depreciation expenses, would be able to deduct more interest, reducing their tax bills.
Why we flagged it
The bill's sole operative mechanism is restoring a more favorable interest-deduction calculation for businesses, reducing their federal tax burden — a targeted tax relief measure for business taxpayers.
What the text implies
- The revenue cost of restoring EBITDA-based ATI is not stated in the bill; estimates from prior debates on this provision suggest it could reduce federal revenues by tens of billions of dollars over a decade, shifting that burden to the general public.
- Capital-intensive industries — real estate, manufacturing, utilities, telecommunications — benefit disproportionately because they carry large depreciation and amortization charges that inflate ATI under the restored standard.
- Highly leveraged private equity-backed companies stand to gain the most, as they typically carry heavy debt loads and large depreciation from acquisition-related amortization, making this a significant windfall for that sector.
- The bill references Public Law 119-21 as the source of the modification being repealed; the full interaction with that law's other provisions is not visible from this text alone and may affect the precise scope of the restoration.
- Restoring EBITDA-based ATI may encourage additional corporate leverage, since the tax penalty for carrying debt is reduced — a potential systemic financial stability concern not addressed in the bill.
Section numbers refer to the bill text the analysis read — linked under Primary records below.
Who it affects
Businesses — especially capital-intensive ones — gain a larger interest deduction, potentially freeing up capital for investment and employment; however, the primary direct benefit flows to corporate and business taxpayers rather than ordinary citizens, and the revenue cost is borne by the public treasury.
Who stands to gain
- capital-intensive corporations (manufacturing, utilities, real estate)
- private equity-backed companies with high leverage
- telecommunications companies
- businesses with significant depreciation and amortization expenses
- real estate investment trusts (REITs)
Named in the bill
Internal Revenue Code Section 163(j), House Committee on Ways and Means, Public Law 119-21, IRS
Where it stands
23 cosponsors: 23 Republicans.
- Mar 26, 2026 — Introduced · Congress.gov: “Introduced in House”
- Mar 26, 2026 — Referred to House Committee on Ways and Means · Congress.gov: “Referred to the House Committee on Ways and Means”
Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.
Money around this bill
12 lobbying clients named this bill on 13 disclosure filings across 2 quarters, Mar 2026 to Jun 2026. Those filings disclosed $49,620,000 in lobbying spend. A filing names 10 bills on average, so that figure is what each filing reported, not a share belonging to this bill.
More lobbying clients named this bill than 93% of bills with at least one filing.
Ron Estes, the sponsor, reported $1,180,334 in PAC receipts in the 2026 cycle. $18,500 of that came from 3 PACs tied to these lobbying clients.
- Chamber of Commerce of the U.S.A. — $36,700,000 on 2 filings
- Business Roundtable Inc — $6,950,000 on 1 filing
- American Chemistry Council — $2,570,000 on 1 filing
- Dell Technologies Inc — $1,490,000 on 1 filing
- Albemarle Corporation — $520,000 on 1 filing
Lobbying Disclosure Act filings through Jul 20, 2026. A filing shows who paid to lobby on a bill it names, not what changed.
How this was measured
Analysis — Quorum's AI read the bill text published by Congress.gov (537 characters) on Apr 3, 2026. Section numbers in the findings refer to that text, linked below; transparency and hidden-provision scores are compared against the median of 16,222 analysed bills.
Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.
Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Mar 2026 to Jun 2026. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.
As of — lobbying records through Jul 20, 2026 · page rendered 2026-10-20.
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