5 Key Ways Trump's Big Beautiful Bill Transforms Corporate Taxation

Forbes

14 hours ago

Tax
The House has passed the Senate's version of Trump's Big Beautiful Bill by a narrow margin (216-214), and it will now head to President Trump's desk for his signature. The bill includes significant tax cuts that dwarf the spending cuts to the tune of a $3.1 trillion increase in the deficit over the next 10 years, according to Forbes. This article highlights 5 key ways the One Big Beautiful Bill Act transforms corporate taxation. For a look at how the bill will affect individual taxation, see my companion article on Forbes.
(1) Corporate Tax Rates Will Not Increase
A key provision of the Tax Cuts and Jobs Act of 2017 lowered the corporate tax rate by a staggering 40% (from 35% to 21%). The previous rate of 35% has been held constant since 1986. However, relative to other OECD countries, the 35% tax rate was among the highest levied on corporations in the OECD. Many companies and policymakers felt this put US corporations at a competitive disadvantage, especially given the increasingly global economy, according to the Tax Policy Center.
Absent a provision allowing the corporate rates to hold steady, they would have reverted to their 35% tax rate. In a statement released by the White House, holding the corporate tax rate at 21% signals a pro-business environment for starting and growing businesses.
(2) Full Expensing Of Domestic Research And Experimentation
Since 2022, corporations have been required to amortize and expense their research and development (R&D) expenses over time. As highlighted by The Tax Foundation, not being able to immediately expense R&D stifles corporate innovation in the US. The One Big Beautiful Bill Act addresses this issue by allowing R&D performed in the US to be immediately expensed. Meanwhile, R&D performed by US corporations outside the US will continue to be subject to the amortization rules.
While separating domestic from international R&D expenses will create other nuances that need to be addressed over time, this provision benefits corporations by allowing the immediate expensing of these costs, yielding significant tax benefits due to the time value of money. This provision enables corporations to recognize expenses earlier, rather than later, thereby benefiting from the time value of money. This provision will also benefit the US by providing financial incentives for corporations to locate their R&D activities within the US.
Lastly, an important portion of this provision is that it will be retroactively implemented as of December 31, 2021. This change means that corporations that have been amortizing their R&D over the last three and a half years can now recognize these expenses. For companies with annual gross receipts of less than $31 million, the expensing can occur immediately. All other companies can recognize these expenses over the next two years.
(3) Bonus Depreciation Is Back
The bonus depreciation benefits, which provide an immediate expense deduction for specified types of property purchased, were introduced by the Tax Cuts and Jobs Act of 2017. These benefits have been slowly phased out in recent years and were scheduled to expire completely in 2027. The One Big Beautiful Bill Act brings back the 100% immediate expensing through 2029.
The property that qualifies for bonus depreciation typically includes tangible personal property, such as furniture and fixtures, computer equipment, appliances, and certain types of vehicles. The immediate expensing allows corporations to realize significant tax benefits by accelerating their tax deductions for qualifying expenditures over many years. Being able to deduct these expenses immediately not only puts the cash flows back in the corporation's hands, but it also gives them a time value of money benefit for their tax deductions.
(4) Reenactment And Amplified Opportunity Zone Tax Benefits
The Tax Cuts and Jobs Act of 2017 introduced the concept of opportunity zones, designed to utilize tax incentives to stimulate investment in underserved communities. According to the Tax Policy Center, opportunity zones had three key tax benefits: (1) temporary deferral of taxes on previously earned capital gains, (2) basis step-up of previously earned capital gains invested, and (3) exclusion of taxable income on new gains.
While the benefits of opportunity zones primarily accrue to high-wealth individuals, many of these opportunity zones have flowed into real estate and operating businesses, representing a potential catalyst for companies that might ultimately become or be acquired by corporations. Importantly, these entities can only be developed and allocated in specific areas, which means that investments are flowing into areas that are most in need of economic stimulus.
The One Big Beautiful Bill Act brings back opportunity zones through 2033. The key changes include that 33% of the zones must be in rural areas (an area with fewer than 50,000 inhabitants), and an increased tax incentive of a 30% exclusion of a deferred gain (previously 10%). Thus, this provision will increase the incentives for wealthy taxpayers to invest in rural areas that may be in need of an economic stimulus.
(5) Less Extreme Changes To Multinational Taxation Rules
Perhaps no bill in history has altered the taxation of US multinationals as significantly as the Tax Cuts and Jobs Act of 2017. In that bill, US multinationals transitioned from a worldwide tax system, where profits generated anywhere in the world were taxed in the US, to a quasi-territorial tax system, where, as long as certain conditions were met, profits were only taxed in the jurisdiction where they were generated. This lowered the complexity for multinational corporation tax laws.
However, other provisions have also now become a mainstay in US multinational tax law, such as the Global Intangible Low-Taxed Income (GILTI) tax, which introduces an additional layer of US tax when companies have unusually high income relative to their assets overseas. The Tax Cuts and Jobs Act of 2017 also introduced the Foreign-Derived Intangible Income (FDII) provision, which provides a lower tax rate for products made in the US and exported overseas. Lastly, the act introduced the Base Erosion Anti-Abuse Tax (BEAT), which adds tax liabilities to large corporations that make significant payments to foreign subsidiaries, such as royalties and interest. Each of these provisions were set to become less beneficial to US corporations starting in 2026.
Under the One Big Beautiful Bill Act, the quasi-territorial tax system will remain in place. The additional layer of GILTI tax will increase from 10.5% to 10.7%. While this increase is higher than 13.1%, it is better than what it would have been absent this bill. Similarly, the lower FDII tax rate was 13.125%, and it would have increased to 16.4%. Instead, it will be 13.3% starting in 2026. Lastly, the BEAT tax rate will increase from 10% to 10.1% under the One Big Beautiful Bill Act, rather than 12.5% under the Tax Cuts and Jobs Act. While some of these changes and modifications may appear small, it is essential to consider the magnitude of the global economy and recognize that even tenths of a percent can have multi-million-dollar ripple effects. Above all else, these changes help ensure our corporations remain competitive in the global economy.
These key changes are not all that is packed into the nearly 1,000-page One Big Beautiful Bill Act. However, they do represent some of the most impactful to US Corporations should President Trump sign it into office on the 4th of July.