The One Big Beautiful Bill Act includes several significant tax provisions that will directly impact large corporations. From capital investment incentives to international tax reforms, here’s a breakdown of the most relevant changes and what they mean for corporate taxpayers.
Tax & AccountingAugust 21, 2025
Key tax provisions for large corporations in the latest 2025 legislation
Bonus depreciation made permanent
What changed:
100% bonus depreciation is now permanent for property acquired after January 19, 2025.
Why it matters:
This change allows corporations to immediately expense the full cost of qualifying capital assets, improving cash flow and reducing taxable income. It’s a major win for capital-intensive industries such as manufacturing, logistics, and energy.
Research and experimental (R&E) expenditures
What changed:
The deduction for domestic R&E costs is permanently reinstated, with a retroactive election option for small businesses.
Why it matters:
Corporations investing in innovation, product development, and technology can now deduct these expenses immediately rather than amortizing them over time. This change encourages continued investment in U.S.-based research.
Qualified business income (QBI) deduction
What changed:
The QBI deduction has been made permanent, with certain modifications.
Why it matters:
Although originally designed for pass-through entities, some large corporations with qualifying subsidiaries or structures may benefit. This provision could influence how corporations structure their operations.
Section 179 expensing
What changed:
Deduction limits under Section 179 have been increased.
Why it matters:
This provision enhances the ability of corporations to expense the cost of equipment and technology investments, further supporting modernization and operational efficiency.
International tax provisions
What changed:
- FDII and GILTI deductions are made permanent, but recharacterized as foreign-derived deduction eligible income (FDDEI) and net CFC tested income (NCTI) deductions, with adjusted rates and definitions.
- The base erosion and anti-abuse tax (BEAT) has been revised.
Why it matters:
Multinational corporations must reassess their global tax strategies, including transfer pricing and profit allocation. These changes may affect decisions on where to locate intellectual property and operations.
IRS procedural changes
Why it matters:
New penalties introduced for Employee Retention Credit (ERC) fraud.
What changed:
Employers should prepare for increased scrutiny and ensure robust compliance frameworks are in place.
Final thoughts
These provisions represent a significant shift in corporate tax policy, with long-term implications for investment, innovation, and international operations. Large corporations should work closely with tax advisors to model the impact of these changes and adjust their strategies accordingly.
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