20 Key Business Tax Provisions Under OBBBA

The One Big Beautiful Bill Act (OBBBA) has made essential changes to stimulate growth, innovation, and investment in businesses. It makes the Section 199A Deduction for pass-through income permanent and restores Bonus Depreciation to 100%, spurring capital investment. R\&D Expensing focuses on innovation more aggressively, and Interest Deductibility at 30% of EBITDA allows for more stable deductibles.  

Incentives for clean energy are revised, with evs and solar receiving less support after 2025. Expansion of equipment deductions with Section 179 is raised to $2.5 million. Encouragement for corporate philanthropy is made with an increased Charitable Deduction limit. Domestic manufacturing is aided through Production Property Expensing. Startup investment is stimulated by raising the QSBS Exclusion to $15M.  

Taxes incentives for Opportunity Zones are extended and contractor reporting thresholds are raised to minimize compliance costs. GILTI Deduction has been made permanent, securing foreign income tax stability. Other provisions include unpaid Family and Medical Leave and Employer-Provided Child Care Credits with enhanced benefits, focused on attracting investment to rural and startup regions.  

All in all, these changes create and foster more stability and predictability while also improving a business friendly climate, boosting investment and growth in the long term. 

Provision 

Definition 

Pre-OBBBA 

Post-OBBBA 

Outcomes for Business 

1. Section 199A Deduction 

20% deduction for qualified pass-through income 

Temporary 20% deduction 

Made permanent with $400 minimum 

Certainty for small businesses and sole proprietors 

2. Bonus Depreciation 

Immediate expensing of qualified property 

60% declining rate 

Restored to 100% and made permanent 

Encourages capital investment 

3. R&D Expensing 

Deduction for research and development costs 

Domestic R&D amortized over 5 years 

Immediate expensing (domestic only) 

Boosts innovation and reduces compliance burden 

4. Interest Deductibility 

Limits on interest expense deduction 

Limited to 30% of EBIT 

Reverts to 30% of EBITDA permanently 

Reduces allowable deductions for leveraged firms 

5. Clean Electricity Credits 

Incentives for renewable energy investments 

Available through 2032 

EV and solar credits end after 2025 

Reduced incentives for solar and EVs 

6. Section 179 Deduction 

Immediate expensing of certain property 

$1.22 million limit 

Increased to $2.5 million 

Expands access to equipment deductions 

7. Charitable Deduction (Corps) 

Deduction for corporate charitable contributions 

Up to 10% of taxable income 

More than 1%, capped at 10%, no minimum 

Encourages corporate giving 

8. Production Property Expensing 

Expensing for domestic production property 

No special provision 

100% expensing for qualified domestic production 

Incentivizes U.S. manufacturing 

9. QSBS Exclusion 

Exclusion of gain on sale of small business stock 

$10M exclusion after 5 years 

Raised to $15M; phased benefits at 3, 4, 5 years 

Enhances startup investment appeal 

10. Opportunity Zones 

Tax incentives for investing in distressed areas 

Scheduled to sunset 

Extended through 2035 

Long-term certainty for OZ investments 

11. 1099 Reporting Thresholds 

Reporting requirements for contractor payments 

$600 threshold 

Raised to $2,000; 1099-K reverts to $20K/200 

Reduces compliance burden 

12. GILTI Deduction 

Deduction for global intangible low-taxed income 

Scheduled changes under TCJA 

Made permanent at 40% 

Predictable foreign income taxation 

13. Energy Tax Credits 

Incentives for clean energy investments 

Expanded under IRA 

Scaled back for fossil fuels 

Shifts focus to clean fuels and nuclear 

14. Excess Business Loss (EBL) Limitation 

Caps deductible losses for noncorporate taxpayers 

Scheduled to expire after 2028 

Made permanent 

Limits tax loss harvesting 

15. Paid Family & Medical Leave Credit 

Employer credit for paid leave wages 

Set to expire after 2025 

Made permanent 

Encourages paid leave programs 

16. Employer-Provided Child Care Credit 

Credit for workplace childcare expenses 

25% credit; $150K cap 

Increased to 40–50%; $500K–$600K cap 

Boosts employee retention 

17. Tiered Excise Tax for Foundations 

Tax on foundation investment income 

Flat 1.39% rate 

Tiered rates based on grant activity 

Encourages charitable distributions 

18. Rural OZ Basis Boost 

Enhanced basis for rural Opportunity Zone investments 

No special rural provision 

30% basis increase after 5 years 

Attracts capital to rural areas 

19. Floor Plan Interest Deduction Expansion 

Deduction for inventory financing interest 

Limited to motor vehicles 

Expanded to trailers and campers 

Benefits dealerships and RV retailers 

20. Startup Payroll Tax Offset 

Allow startups to offset payroll taxes with R&D credits 

$250K annual cap 

Increased to $500K for qualified startups 

Improves cash flow for early-stage companies 

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