July 15, 2025

The One Big Beautiful Bill Act spans more than 800 pages and rewrites entire sections of the Internal Revenue Code, from individual rates to international sourcing rules. In the space below, we focus on the provisions most likely to matter to privately held companies and their owners—enough detail to help you spot planning opportunities, but concise enough to read over a coffee break. As always, every business has its own facts and goals, so view this as a roadmap for deeper conversation with your Omni 360 advisory team.

 How we got here

After clearing the House on May 22 and the Senate on July 1, the “One Big Beautiful Bill Act” landed on the President’s desk just in time for Independence Day. Donald J. Trump signed it on July 4, 2025, ushering in the most sweeping rewrite of the Internal Revenue Code since 2017.  

1. Permanent lower tax rates & a sturdier §199A deduction

The individual-rate schedule (which flows through to most pass-throughs) is locked in, and the 20 % Qualified Business Income (QBI) deduction now phases in above $75 k single / $150 k joint, with a $400 minimum that indexes for inflation.
Impact for business owners: predictable marginal rates and a more reliable QBI deduction make long-range planning and entity-choice modeling simpler.

2. Full expensing & turbo-charged cost recovery

• 100 % bonus depreciation is permanent for most tangible business property placed in service after 1/1/25.
• §179 expensing limit climbs to $2.5 million (phase-out starts at $4 million) and will index going forward.
• New §168(n) allows 100 % write-off of qualified production real property—think factories, warehouses, distribution hubs.
• Up-front expensing (up to $150 k per project) for sound-recording productions joins the pool, and domestic R&D outlays are again fully deductible in the year paid.
  Impact for business owners: growth investments—from a new CNC machine to a green-field plant—can drop straight to the bottom line in year one, freeing cash for expansion, debt reduction, or owner distributions.

3. A friendlier interest-expense & financing landscape

• EBITDA add-back is restored in the §163(j) limitation, expanding deductible interest capacity.
• A technical fix now excludes disallowed §163(j) interest from UNICAP calculations, preventing double hits for inventory producers.
  Impact for business owners: more room to borrow (or refinance) without tripping tax caps or distorting inventory costs.

4. Qualified Small Business Stock (QSBS) super-charged

For stock issued after July 4, 2025:

• Lifetime gain exclusion per issuer jumps from $10 M to $15 M and will index for inflation.
• Asset-size ceiling for “small-business” status rises to $75 M, also indexed.
• Tiered exclusions reward shorter holds—50 % after 3 years, 75 % after 4 years, and 100 % after 5 years—and excluded gains remain outside the Alternative Minimum Tax.
  Impact for business owners: issuing QSBS can attract growth capital on better terms, and founders planning exits may shelter much larger gains—sometimes even on earlier sales.

5. Reporting relief & red-tape cuts

• 1099-MISC/NEC threshold jumps from $600 to $2,000 (indexed).
• Third-party network de-minimis revives the $20 k / 200-transaction rule for 1099-K.
• Corporations now deduct charitable gifts only to the extent they exceed a new 1 % taxable-income floor.
  Impact for business owners: simpler paperwork, fewer surprise 1099s, and cleaner budgeting for philanthropy.

6. People-first incentives & HR budget relief

• Paid Family & Medical Leave credit is permanent and now counts third-party insurance premiums.
• Employer child-care facilities credit rises to 40 % (50 % for small businesses) of up to $500 k in qualified costs, indexed.
• Dependent-care assistance exclusion increases to $7,500 (indexed).
• Employer student-loan payments up to $5,250 remain tax-free, permanently.
• Adoption credit becomes refundable up to $5 k.
• Executive-pay limit (§162(m)) now aggregates compensation across related entities; the “top-five” list widens in 2027.
  Impact for business owners: richer credits and higher exclusions reduce the after-tax cost of key benefits, helping you recruit and keep talent in a competitive market.

7. Industry-specific breaks

• Spirits, wine & hospitality: A permanent $13.25 per proof-gallon cover-over on distilled-spirits excise tax—hailed by fourteen national spirits, winery and hospitality groups—should lower costs through the supply chain.
• Advanced manufacturing: The advanced-manufacturing investment credit rate jumps to 35 % after 2025, dovetailing with full expensing for new facilities and equipment.
• Construction & real estate: Builders completing residential projects within three years can now elect out of percentage-of-completion accounting, smoothing taxable income on shorter developments.
  Impact for business owners: sector-specific incentives (and, for beverage producers, direct tax relief) can materially affect project ROI and pricing strategy—worth a fresh look before budgeting 2026 capital.

8. Green-credit rollbacks & energy-sector carve-outs

Many Inflation Reduction Act incentives sunset early or tighten prohibited-foreign-entity rules (§45Y, §48E, §45V). Meanwhile, select energy projects (hydrogen, carbon capture, advanced nuclear) keep enhanced credit rates—but with new sourcing hurdles and clawbacks.
Impact for business owners: energy projects and fleet conversions must move quickly or re-model costs under narrower credit windows.

9. Estate & Gift Tax Exemption Permanently Raised

The lifetime estate-and-gift tax exemption, which was scheduled to fall back to roughly $6 million per person in 2026, is permanently increased to $15 million per person (indexed for inflation) beginning with deaths and gifts after 2025. Portability remains, allowing married couples to shield up to $30 million of combined assets.

Impact for business owners: A larger, inflation-proof exemption gives owners more room to transfer company interests, fund buy-sell agreements, or set up dynasty trusts without triggering transfer taxes—opening the door to earlier, tax-efficient succession planning.

The bottom line

OBBB 2025 rewards companies that invest in growth, talent and U.S.-based production—while dialing back some pandemic-era credits and clean-energy perks. Omni 360 Advisors is already modeling these changes across entity structures, financing mixes and succession plans.

Want to be sure you’re capturing every opportunity—or avoiding new pitfalls?
Reach out to your Omni 360 advisory team, or flag these topics for your next strategy meeting. We’re here to keep your business ahead of the curve.

This post is for educational purposes only and is not legal or tax advice. Consult your professional advisors about your specific circumstances.