TZL 1593 (web)

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OPINION

New tax law creates major planning opportunities – R&D, bonus depreciation, and corporate rates shift, with key deadlines looming. Insights from the One Big Beautiful Bill

W hen new legislation rolls out, especially one as sweeping as the recently passed One Big Beautiful Bill Act, there’s a lot of excitement, confusion, and critical need for interpretation.

Stambaugh Ness’ recent webinar, available now, breaks down what we know so far, and, most importantly, what your business should be doing next. We’re still early in the implementation phase, and while the intended changes to tax law are clear, the devil is in the details, as the saying goes. We now need to look to rule makers to clarify and provide procedural steps for implementation. That said, here’s a recap of the key insights you need to know. A QUICK HISTORY: HOW WE GOT HERE. The groundwork for this bill dates to the 2017 Tax Cuts and Jobs Act, which introduced a variety of business and individual tax cuts, many of which were set to sunset by the end of 2025. The new bill resets the playing field, making many of those expiring provisions permanent and introducing changes across business and individual taxation, incentives, and expensing. WHAT’S STAYING. TCJA provisions made permanent: ■ Flat corporate rate: The 21 percent flat corporate tax rate remains and is now permanently codified, replacing the old graduated system.

R&D EXPENSING: GAME-CHANGER FOR INNOVATION INVESTMENT. One of the biggest wins in the bill is the return of full expensing for domestic research and experimentation, or R&E, starting after December 31, 2024. This allows companies to immediately deduct eligible R&D costs, an enormous cash flow and strategic

Jennifer Nelson, CPA, MBA

planning opportunity. Key elements include:

■ Section 174A: Newly introduced for permanent expensing of domestic R&E. ■ Section 174 amended: Foreign research costs must still be amortized over 15 years. ■ Retroactive opportunity: Small businesses (under $31M in average gross receipts for the prior three years) may choose to amend returns to capture deductions pre-2025.

Expensing post December 31, 2024: † Firms over $31M gross revenue threshold can recoup the capitalized expenses on returns filed for tax years beginning after December 31, 2025 either fully in one year, over two years, or over the remaining amortization period. † Firms under the $31M gross revenue threshold can also elect to recoup the capitalized expenditures in the same manner as large taxpayers (in lieu of amending returns).

ACA penalty repeal: The Affordable Care Act penalty tax is permanently removed.

■ Expanded deduction landscape: Several key TCJA tax provisions (R&D expensing, bonus depreciation, and qualified business income deductions) are now permanent fixtures.

See JENNIFER NELSON , page 4

THE ZWEIG LETTER JULY 14, 2025, ISSUE 1593

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