The landscape of U.S. business taxation has shifted once again. With the passage of the **One Big Beautiful Bill—now formally the 2025 Act—**Congress has reset the rules for how American companies invest, innovate, and compete. For CFOs, finance directors, and tax professionals, these changes are more than technical adjustments: they create both opportunities and responsibilities.
What sets this law apart is not just the scale of its provisions, but its intent. Instead of temporary patches and cliff-edge expirations, the 2025 Act provides a durable framework that emphasizes certainty, clarity, and long-term planning. Many long-standing ambiguities are resolved, and in several areas, businesses can now model their tax strategy with a level of predictability that has been missing for years.
This seven-article series will walk through the most important takeaways for U.S. businesses, with a focus on what finance leaders need to understand and act upon. Here’s a preview of what we’ll cover:
1. Research and Experimentation (R&E) Expensing
The Act restores immediate expensing for domestic R&D, ending the unpopular five-year amortization. At the same time, it leaves foreign research on a 15-year track, creating a sharp incentive to keep labs in America. We’ll explore the mechanics of the new §174A, the IRS’s transition guidance, and the special relief for small businesses.
2. Manufacturing Investment Credit (Semiconductors and Beyond)
Congress has raised the Advanced Manufacturing Investment Credit from 25% to 35% for qualifying property placed in service after 2025. This strengthens the economics of U.S. semiconductor fabs and supply-chain projects, reinforcing America’s industrial base. We’ll look at the history of §48D, the new rules, and how firms can maximize the benefit.
3. Interest Expense Limitations
The interest deduction rules are now firmly tied to earnings capacity, with EBITDA restored as the benchmark from 2026 onward. These changes align the deduction with real operating performance and close off loopholes, while offering relief for small businesses and clarity for partnerships. We’ll break down how the new rules work in practice.
4. International Taxation Overhaul
Complex acronyms like GILTI and FDII are rebranded and simplified, expense allocations are cleaned up, and the foreign tax credit limit is eased. Companies can now claim credit for 90% of foreign taxes paid, a meaningful step toward fairness. We’ll analyze what this means for multinationals and why the changes represent a more workable system.
5. Exporting Manufacturers and Sourcing Rules
Section 70313 sets a 50% ceiling on how much profit from U.S.-produced goods sold abroad can be sourced as foreign income. While not perfect, this at least provides predictable relief for foreign tax credits. We’ll examine how exporters should model the impact and what this means for industries where overseas sales drive value.
6. Credit for Paid Family and Medical Leave
Once a temporary pilot, §45S is now permanent, with broader eligibility and new flexibility. Employers can claim the credit either through wages paid during leave or premiums on paid-leave insurance policies. We’ll explain how the new credit works, how it coordinates with state programs, and why it’s both a compliance requirement and a retention strategy.
7. 100% Expensing and Section 179 Enhancements
Perhaps the most sweeping change: permanent full expensing for qualifying assets under §168(k). Combined with higher §179 limits, this gives manufacturers and other capital-intensive businesses unprecedented certainty for modernization, automation, and capacity expansion. We’ll outline the mechanics, planning opportunities, and how to align tax strategy with capital budgets.
Why This Matters
Taken together, these provisions reset the tax baseline for U.S. businesses. They encourage domestic innovation, capital investment, and workforce support, while reducing uncertainty and compliance disputes. Finance leaders now have the chance to model long-term tax strategies with confidence, aligning operations and investment decisions with a more stable framework.
The message from Washington is clear: if you invest in America—whether in research, factories, people, or global competitiveness—the tax code will now reward you with upfront clarity and stronger incentives.
Join the Conversation
This series is designed to help you, as CFOs, finance directors, and tax professionals, navigate the new rules and put them to work for your businesses and clients. Each article will break down the technical details, highlight practical examples, and give you the insight needed to adapt.
We welcome your feedback, questions and ideas, comment below or email us at info@ifindtaxpro.com.
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