2025 has been a remarkable year for corporate and tax law in the United States. On Independence Day President Trump signed the One Big Beautiful Bill Act (OBBBA), a far‑reaching tax overhaul that permanently extends many of the expiring provisions from the Tax Cuts and Jobs Act (TCJA) and introduces new incentives. Here’s what practitioners need to know about the major provisions:
- Bonus depreciation becomes permanent instead of phasing down after 2026. Businesses can continue to deduct 100 % of eligible property costs in the year the property is placed in service.
- Expanded Section 179 expensing—OBBBA raises the maximum Section 179 deduction to $2.5 million (from $1.16 million) and indexes it for inflation.
- Research credit refundability—the R&D tax credit can now be refunded for both payroll and income tax, providing immediate cash benefits to small and mid‑sized companies.
- US manufacturing super‑credit—companies that produce semiconductors, renewable‑energy components or critical technologies in the United States can claim a 30 % credit on qualified expenditures.
- Opportunity zone extensions—investors have until 2030 to defer capital‑gains taxes by investing in qualified opportunity zone projects.
2. Corporate Transparency Act rollback
In a surprise move, the Treasury and FinCEN effectively gutted the Corporate Transparency Act reporting rules in March 2025 by exempting companies formed or registered in the United States from filing beneficial ownership reports. Only foreign entities are now required to report beneficial owners. However, companies that previously filed must still update information if there are changes. Congress has hinted at legislation to restore some domestic reporting requirements, but no bills have advanced.
3. Loper Bright and the end of Chevron
The Supreme Court’s June 2025 decision in Loper Bright Enterprises v. Raimondo overruled the Chevron doctrine, which had required courts to defer to reasonable agency interpretations of ambiguous statutes. In its place, courts must now conduct de novo reviews of agency interpretations unless Congress explicitly delegates interpretive authority to an agency. This shift will likely invite more challenges to administrative regulations and create uncertainty as courts recalibrate standards of review. Companies should expect more litigation when agency rules are at issue.
4. Practical tips for practitioners
- Review tax models to incorporate OBBBA’s permanent bonus depreciation, increased Section 179 limits and new credits. Factor in the potential cash‑flow benefits of refunding research credits.
- Monitor CTA developments—although domestic reporting is suspended, Congress may reinstate some obligations. Ensure companies maintain ownership records in case new requirements are enacted.
- Prepare for regulatory challenges—agencies may revise or withdraw rules to avoid litigation under Loper Bright. Evaluate whether existing regulations remain sound without Chevron deference, particularly when advising on environmental, labor or financial rules.
As the year comes to a close, companies should seize the tax incentives available under OBBBA, stay engaged on transparency reforms, and anticipate a more active role for courts in reviewing agency regulations. Your strategic advice can help clients navigate these shifts and capitalize on new opportunities.
