Business Taxation.

The One Big Beautiful Bill Act delivers a major overhaul to the business tax landscape, shaping an environment that prioritizes investment, innovation, and operational growth. By making key incentives permanent and enhancing existing deductions, the legislation reduces tax uncertainty and encourages long-term planning. Companies now have more access to immediate cash flow when making investments and hiring decisions, fueling the potential for expansion and increased productivity across industries.

A core theme of the Act is simplification and predictability. With streamlined rules for deductions, international earnings, and R&D spending, businesses can make more strategic choices about where and how to invest—in equipment, employees, or new markets—without being hampered by changing tax restrictions or temporary incentives. This predictability particularly benefits enterprises looking to scale or diversify their operations globally.

Ultimately, the legislation is expected to increase economic growth by reducing the barriers for investing, aligning the US with global tax practices, and fostering an innovative climate. By easing compliance and boosting after-tax returns, the Act allows businesses to take greater risks, drive technological development, and contribute more to economic growth.

TL;DR for Small/Medium Businesses

The new legislation provides a major boost for small and medium-sized businesses by making tax rules more favorable for growth and reinvestment. With more generous and permanent deductions, especially for business income, equipment purchases, and research spending, companies benefit from immediate tax savings and improved cash flow. This means they can reinvest in new tools, technology, or hiring sooner, which supports their long-term expansion and competitiveness.

Additionally, the simplified and enhanced tax structure reduces uncertainty and compliance burdens. Businesses can make decisions about investing in their operations or innovating new products with greater confidence, knowing the tax environment will remain consistent. Overall, these changes are designed to create a more dynamic and opportunity-rich setting for growth-minded entrepreneurs and established companies alike.

TL;DR for Medium/Large Businesses

The new legislation provides a major boost for small and medium-sized businesses by making tax rules more favorable for growth and reinvestment. With more generous and permanent deductions, especially for business income, equipment purchases, and research spending, companies benefit from immediate tax savings and improved cash flow. This means they can reinvest in new tools, technology, or hiring sooner, which supports their long-term expansion and competitiveness.

Additionally, the simplified and enhanced tax structure reduces uncertainty and compliance burdens. Businesses can make decisions about investing in their operations or innovating new products with greater confidence, knowing the tax environment will remain consistent. Overall, these changes are designed to create a more dynamic and opportunity-rich setting for growth-minded entrepreneurs and established companies alike.

Qualified Business Income Deduction (§70105)

  • The Act makes the 20% qualified business income deduction permanent, expands the phase-in ranges for limitations, and establishes a minimum $400 deduction for qualifying taxpayers.

  • The TCJA created the QBI deduction through 2025, with phase-in ranges of $50,000 for single filers and $100,000 for married filing jointly.

  • Permanent, with enhancements effective January 1, 2026.

  • The phase-in ranges increase to $75,000 for single filers and $150,000 for married filing jointly. The minimum deduction applies to taxpayers with at least $1,000 in qualified business income who materially participate in the business.

  • This provision provides significant benefits to small business owners and independent contractors. The expanded phase-in ranges allow more high-income taxpayers to benefit, while the minimum deduction ensures meaningful relief for smaller businesses. The permanent nature encourages business formation and investment.

Bonus Depreciation Restoration (§70301)

  •  The Act permanently restores 100% bonus depreciation for qualified property acquired after January 19, 2025.


  • Bonus depreciation was scheduled to phase down to 40% in 2025, 20% in 2026, and 0% in 2027.


  • Permanent, effective January 19, 2025.


  • The provision applies to tangible personal property with a recovery period of 20 years or less, plus certain qualified improvement property. A new category of "qualified production property" also receives 100% bonus depreciation.


  • This provision provides significant incentives for business investment and expansion. The permanent nature gives businesses certainty for long-term planning, while the immediate deduction improves cash flow and return on investment. The addition of qualified production property encourages domestic manufacturing.


  • The Act permanently allows immediate deduction of domestic research and development expenses while requiring 15-year amortization for foreign R&D.

  •  Since 2022, the TCJA required all R&D expenses to be amortized over five years (domestic) or 15 years (foreign).

  • Permanent, effective for tax years beginning after December 31, 2024.

  • Small businesses meeting the $31 million gross receipts test can elect to deduct R&D expenses retroactively to 2022. Large businesses can elect to accelerate previously capitalized expenses.

  • This provision significantly benefits innovation-driven businesses by improving cash flow and returns on R&D investments. The preference for domestic R&D creates incentives for companies to conduct research in the United States. The retroactive election provides relief for businesses that have been adversely affected by the capitalization requirement.

Research and Development Expensing (§70302)

Business Interest Deduction (§70303)

  • The Act permanently modifies the business interest limitation calculation by removing depreciation, amortization, and depletion from adjusted taxable income.

  • The TCJA temporarily allowed these deductions in the Adjusted Taxable Income calculation through 2021, after which they were removed, making the limitation more restrictive.

  •  Permanent, effective for tax years beginning after December 31, 2024.

  •  The change increases the amount of business interest that can be deducted by raising the calculation base for the 30% limitation.

  • This provision provides meaningful relief for capital-intensive businesses, particularly those with significant depreciation deductions. The permanent nature provides certainty for business financing decisions and may encourage additional investment in productive assets.

§179 Expensing Enhancement (§70306)

  • The Act increases the §179 deduction limit to $2.5 million with a phase-out threshold of $4 million

  •  The TCJA set the §179 limit at $1 million with a phase-out starting at $2.5 million in equipment purchases.

  • Permanent, effective January 1, 2025.

  • The provision applies to qualifying equipment purchases by small businesses, allowing immediate deduction rather than depreciation.

  • This enhancement provides significant benefits to small businesses by improving cash flow and simplifying tax compliance. The higher limits allow more businesses to benefit from immediate expensing, encouraging equipment purchases and business expansion.

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Individual Taxation