Navigating the new tax compliance era: Key changes for corporations under the OBBBA

The One Big Beautiful Bill Act (OBBBA), enacted on July 4, 2025, ushers in a new era of corporate tax compliance and planning. The legislation makes permanent several favorable business provisions from the Tax Cuts and Jobs Act while introducing new reporting, payroll, and documentation expectations that will materially affect corporate tax departments beginning in the 2026 filing season. Corporate tax leaders must now balance enhanced incentives — such as 100% bonus depreciation and immediate domestic R&E expensing — with heightened compliance and operational rigor.

Key corporate tax changes

The OBBBA permanently restores 100% bonus depreciation for qualifying property placed in service after January 19, 2025, improving cash flow and capital investment planning. It also reinstates immediate expensing of domestic research and experimentation costs, reversing the prior amortization requirement. Additionally, the Act returns the business interest expense limitation under IRC Section 163(j) to an EBITDA-based calculation, benefiting capital-intensive businesses. Significant modifications to international tax regimes, including GILTI, FDII, and BEAT, further require multinational corporations to reassess global tax structures.

New compliance and reporting expectations

While several new deductions under the Act apply at the individual level, employers play a critical role in capturing and reporting the underlying payroll data. Beginning in 2026, payroll systems must accurately identify and track qualified overtime and tip income to support employee deductions. The Act also expands third-party transaction and digital asset reporting, increasing the volume and complexity of information returns that corporate tax departments must manage.