Facilitating Useful Loss Limitations to Help Our Unique Service Economy (FULL HOUSE) Act
Summary
What This Bill Does
The FULL HOUSE Act changes section 165(d) of the Internal Revenue Code. It returns to a rule under which losses from wagering transactions are allowed only up to the amount of gains from wagering transactions. The bill expressly includes any deduction otherwise allowable under the tax code that is incurred in carrying on a wagering transaction, which means gambling-related business expenses are included in the wagering-loss cap. The change applies for taxable years beginning after December 31, 2025.
Who Benefits and How
Federal taxpayers and Treasury revenue interests benefit because professional gambling losses and related deductions would no longer offset income beyond gambling gains. IRS examiners benefit from a simpler statutory rule that places wagering losses and wagering-business deductions under one cap. Casinos and gaming businesses may benefit indirectly if the rule reduces aggressive deduction strategies that blur gambling expenses and non-gambling income.
Who Bears the Burden and How
Professional gamblers, high-volume bettors, and taxpayers with wagering-business expenses bear the burden because travel, subscriptions, entry fees, and other otherwise deductible expenses tied to wagering cannot reduce taxable income beyond wagering gains. Tax preparers and gambling taxpayers must track gains, losses, and related deductions under the restored cap. IRS guidance staff may need to update forms, instructions, and audit materials for tax years after 2025.
Key Provisions
- Amends Internal Revenue Code section 165(d) to cap wagering losses at wagering gains.
- Includes otherwise allowable deductions incurred in carrying on wagering transactions inside the cap.
- Applies the restored rule to taxable years beginning after December 31, 2025.
- Requires gambling taxpayers and preparers to treat wagering expenses as part of the loss limitation.
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.
At a Glance
What This Bill Does
Restores the Internal Revenue Code wagering-loss rule so losses from wagering transactions, including otherwise allowable wagering-business deductions, may be deducted only to the extent of wagering gains for taxable years beginning after December 31, 2025.
Key Policy Areas
Tax, Gaming
Primary Purpose
Restores the Internal Revenue Code wagering-loss rule so losses from wagering transactions, including otherwise allowable wagering-business deductions, may be deducted only to the extent of wagering gains for taxable years beginning after December 31, 2025.
Policy Domains
Substantive provisions
Identified Gains
- Federal taxpayers
- Treasury revenue officials
- IRS examiners
- Casinos
- Gaming businesses
Identified Costs
- Professional gamblers
- High-volume bettors
- Tax preparers
- IRS guidance staff
Sponsors
Legislative Progress
In CommitteeMr. Miller of Ohio (for himself and Mr. Horsford) introduced …
Referred to the House Committee on Ways and Means.
Introduced in House
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
Professional gamblers and wagering businesses claiming wagering-related deductions
Federal government collecting income tax on wagering activity
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
Learn more about our methodology