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California Non-Conformity to the One Big Beautiful Bill Act (OBBBA)

  • Writer: Viktoriya Barsukova, EA, MBA
    Viktoriya Barsukova, EA, MBA
  • Jul 27
  • 2 min read

California Non-Conformity to the One Big Beautiful Bill Act (OBBBA)
California Non-Conformity to the One Big Beautiful Bill Act (OBBBA)

Because California only currently conforms to the Internal Revenue Code as in effect on January 1, 2015, California will not automatically conform to any of the changes made by the One Big Beautiful Bill Act (OBBBA).


This would be true even if SB 711 is enacted, which, as it’s currently written, would update California’s conformity specified date from January 1, 2015, to January 1, 2025. This is because OBBBA was not enacted until July 4, 2025.


Also, many of SB 711’s provisions would specifically not conform to most of the significant changes made by the Tax Cuts and Jobs Act (TCJA).



2025 California Tax Return Adjustments Due to Non-Conformity


Due to California’s current non-conformity to the tax changes made by OBBBA, additional adjustments will be required on the 2025 California tax return, including:


  • Senior Personal Exemption Deduction

  • Qualified Tip Deduction

  • Qualified Overtime Deduction

  • Deduction for Interest on Qualifying Passenger Vehicle Loans

  • Enhanced Personal Casualty Losses for Disaster Victims

  • Tax-Free Treatment of Withdrawals from IRC §529 Plans to cover:


    • Qualified Credential Program Expenses

    • Additional K–12 School Expenses



Los Angeles wildfire
California Non-Conformity to the One Big Beautiful Bill Act (OBBBA)

Disaster Relief – Wildfire Victims (Federal vs. California Treatment)


As a result of changes made by OBBBA, Los Angeles wildfire victims now qualify for Enhanced Personal Casualty Deductions applicable to Qualified Disaster Losses on their federal tax returns:


  • The 10% AGI floor on net casualty losses is not applicable

  • The $100 per casualty limit is increased to $500

  • Non-itemizers can claim the Personal Casualty Loss


However, California does not currently conform, meaning:


  • The 10% AGI floor still applies

  • The $100 per casualty limit remains in place

  • Non-itemizers cannot claim the Personal Casualty Loss



Other Areas of Continued Non-Conformity


California has never conformed to the following provisions—neither under TCJA nor under OBBBA:


  • Bonus Depreciation

  • Increased §179 Expense Amounts

  • Business Interest Limitation

  • Qualified Small Business Stock Exclusion


As a result, adjustments continue to be required for these items on the California return.


Exception – Research Expenses


Because California never conformed to the TCJA’s requirement that taxpayers amortize research expenses, OBBBA’s reinstatement of current expensing for domestic research expenses may actually result in one fewer adjustment on the California return.


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