USE CASE · TAX TREATMENT · MAY 2026
The TCJA Rule in Plain English (Post-2017, Through 2025)
For most of the last four decades, interest on home equity debt was deductible regardless of how the borrower used the proceeds. The Tax Cuts and Jobs Act of 2017 (Public Law 115-97) reset that. From tax-year 2018 onward, interest on a HELOC or home equity loan is deductible only when the funds are used to buy, build, or substantially improve the home that secures the loan. This page walks through the rule, the 750,000 dollar cap, the tracing burden, three worked examples, and the open question of what happens when TCJA's individual provisions are scheduled to sunset.
The Statutory Frame
The governing statute is Internal Revenue Code section 163(h), which limits the personal interest deduction generally and then defines "qualified residence interest" as deductible. Within qualified residence interest, two categories matter: acquisition indebtedness (debt incurred to acquire, construct, or substantially improve a qualified residence and secured by it) and home equity indebtedness (debt secured by a qualified residence other than acquisition indebtedness).
TCJA, for tax years 2018 through 2025, suspended the deduction for interest on home equity indebtedness regardless of purpose. The acquisition indebtedness deduction remains, with the cap reduced from 1 million dollars (pre-TCJA, still applicable to mortgages originated before 16 December 2017) to 750,000 dollars for post-2017 originations. Critically, a HELOC or HEL used to substantially improve the residence securing the loan counts as acquisition indebtedness even though it is structurally a second mortgage.
The IRS interprets and administers these rules through Publication 936, which is the practical document most preparers and DIY filers reference. The 2018-vintage Notice 2018-32 also clarified that the substantial-improvement use of HELOC proceeds remains deductible under the new framework.
The 750,000 Dollar Combined Cap
The cap applies to combined acquisition indebtedness across all qualified residences (primary plus one second home). It is not a per-loan cap. If your original purchase mortgage is 700,000 dollars and you add a HELOC of 100,000 dollars used to substantially improve the same home, your combined acquisition indebtedness is 800,000 dollars. Interest on the first 750,000 is deductible; interest on the remaining 50,000 is not.
For pre-2018 mortgages, the grandfathered cap is 1 million dollars, and refinancing the original mortgage does not lose grandfathered status as long as the new loan does not exceed the original principal at the time of refinancing. A 1991-vintage 900,000 dollar mortgage refinanced in 2024 retains the 1 million cap for the 900,000 outstanding; a HELOC added on top would face the 750,000 reduced cap for the cumulative balance above 900,000 if used for substantial improvement. This gets complex; consult a CPA or enrolled agent for any high-balance scenario.
For most borrowers with mortgages under 600,000 dollars and HELOCs under 100,000 dollars, the cap is not a binding constraint. The substantial-improvement use test is the binding constraint.
What Counts as Substantial Improvement
Publication 936 borrows the definition from Pub 530 and the broader capital improvement rules used for basis adjustment under section 1016. An improvement is substantial if it materially adds to the value of the home, prolongs its useful life, or adapts it to new uses. Routine repairs that keep the home in ordinary efficient operating condition do not qualify even though they may be necessary to preserve the home's value.
Examples that typically qualify: a new roof (full replacement, not patching), a room addition, a kitchen remodel (not just refacing cabinets), a bathroom remodel (going beyond fixtures), a finished basement, a new central HVAC system, new windows throughout the home, a new septic system, a fence around the property, a built-in pool, landscaping representing a permanent improvement.
Examples that typically do not qualify: painting (interior or exterior, unless part of larger renovation), patching the roof, replacing a few windows, replacing a single appliance not part of a remodel, fixing plumbing, repairing the driveway, routine HVAC servicing. The line is sometimes fuzzy; for grey areas (a high-end appliance package installed during a kitchen refresh, for instance), consult a tax professional and keep documentation.
The Tracing Burden
A HELOC is a revolving line. If you draw 30,000 dollars for a kitchen remodel and another 10,000 dollars for a vacation and credit-card payoff, only the 30,000 portion is acquisition indebtedness. The interest deduction is prorated based on the share of the line attributable to qualifying use. The IRS expects you to be able to prove the tracing if asked, which means documentary records: contractor invoices, materials receipts, a project budget, bank-statement traces of HELOC draws to vendor payments.
One practical approach: open a dedicated checking sub-account that only receives HELOC draws and only pays renovation vendors. This creates a clean paper trail. Another approach: keep a spreadsheet log of every draw, the amount, and the qualifying use, updated within a few days of each draw. The IRS audit standard is contemporaneous documentation; pulling together records four years after the fact tends to be harder and less persuasive.
For a home equity loan (lump-sum disbursement at closing), tracing is simpler. The lender disburses the full amount; you spend it. Keep the contractor invoices showing where the proceeds went and that is usually sufficient. The simpler tracing is one reason HELs are sometimes preferred for substantial-improvement use when tax deductibility matters.
Worked Examples
Example A: Full HELOC used for kitchen remodel
Mortgage balance 400,000. New HELOC opened at 75,000, fully drawn over six months for a kitchen remodel that exceeds substantial-improvement threshold. Combined acquisition indebtedness 475,000, well below 750,000 cap. All HELOC interest is deductible. Annual interest at 9 percent on average 75,000 balance is roughly 5,950 dollars. For a borrower itemising with a 32 percent marginal rate, the federal tax savings is roughly 1,900 dollars.
Example B: HELOC split between renovation and debt consolidation
HELOC of 100,000 drawn 60,000 for renovation, 40,000 for credit card consolidation. Only the 60 percent attributable to renovation is deductible. Annual HELOC interest of 9,000 dollars yields a deductible portion of 5,400 dollars. At 24 percent marginal rate, federal tax savings is roughly 1,296 dollars. The 40,000 dollar consolidation portion produces no deduction and the after-tax cost of that borrowing is the full HELOC rate.
Example C: Standard deduction borrower
HELOC of 50,000 used entirely for substantial improvement. Borrower's total itemisable deductions including the HELOC interest sum to 12,000 dollars. The 2026 standard deduction for married filing jointly is 30,000 dollars. The borrower takes the standard deduction. The HELOC interest produces no tax benefit because itemising is not advantageous. This scenario is common; many homeowners now use the standard deduction post-TCJA's expansion. The deductibility of the interest is theoretical; the actual benefit is zero unless other itemisable deductions push total above the standard.
The 2026 Sunset Question
Many of TCJA's individual-tax provisions were enacted with a sunset date of 31 December 2025, by design. This was done partly to comply with Senate budget-reconciliation rules and partly to ease the political path to enactment. The mortgage interest deduction reduction from 1 million to 750,000 dollars and the suspension of home-equity-indebtedness deduction are among the provisions affected.
What happens in tax-year 2026 depends entirely on legislative action by the end of 2025 (and, since this page is dated May 2026, the outcome should already be settled in current IRS guidance, which readers should check against their tax-year-2026 filing window). Possible outcomes: full extension of the TCJA framework (most likely; consequentially the 750,000 cap and the substantial-improvement-only home-equity rule persist), full reversion to pre-TCJA rules (HELOC interest broadly deductible up to 100,000 dollars regardless of use, 1 million cap on acquisition indebtedness), or a hybrid compromise.
For current-year tax filing, consult the current Publication 936 for the applicable year and the relevant IRS notices. For long-term renovation financing decisions, build a planning case that assumes the TCJA framework continues; that is the most likely outcome given the political path of the 2025 negotiations to date.
Practical Filing Steps
HELOC and HEL interest is reported on Schedule A of Form 1040, in the home mortgage interest section. The lender issues Form 1098 each January showing interest paid. The 1098 does not distinguish between deductible-purpose and non-deductible-purpose use; the burden of allocation is on the borrower.
Three documents to retain: the loan documents establishing the lien on the qualifying residence; contemporaneous records of draw use (renovation invoices, contractor agreements, materials receipts); and any prior-year filings claiming the deduction. Keep these for at least seven years after filing.
If you are unsure whether a specific use qualifies, the cost of a one-hour consultation with a CPA or enrolled agent is typically 150 to 350 dollars. For a HELOC of 75,000 or more where the deduction is meaningful, this is straightforward to recoup.
Frequently Asked Questions
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Not tax or mortgage advice. Tax law changes; verify current rules against the most recent IRS Publication 936 and consult a CPA or enrolled agent for your specific situation. Rates and rules current May 2026.