2025 One Big Beautiful Bill Tax Legislation Update

Forvis Mazars

November 19, 2025

Services may include investment advisory services provided by Forvis Mazars Wealth Advisors, LLC, an �SEC-registered investment adviser, and/or accounting, tax, and related solutions provided by Forvis Mazars, LLP.

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Agenda

1. About Forvis Mazars
2. Select Individual & Trust Provisions
3. Select Business Provisions
4. Select Credit & Other Provisions

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Who we are

At a glance

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18 November 2025

100+

40,000+

combined offices

400+

countries and territories

combined professionals

US$5bn+

1,800+

combined revenue*

combined partners

Forvis Mazars is the brand name for the Forvis Mazars Global network (Forvis Mazars Global Limited) and its two independent members: Forvis Mazars Group SC, an internationally integrated partnership operating in over 100 countries and territories and Forvis Mazars LLP in the United States.

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*Forvis Mazars Group $3,251m + Forvis Mazars, LLP $1,939m as at 31 August 2024

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Select Individual & Trust Provisions

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The Act

Individual & Trust Provisions

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The Act

Individual & Trust Provisions

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**Trust deductions such as fiduciary, administrative, and investment expenses were not changed by the Act.

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The Act

SALT

Cap & PTET

• The Act temporarily raises the SALT cap from 2025 through 2029.
• $40,000 in 2025.
• In years 2026 through 2029, the cap increases by 1% per year.
• In 2030 and thereafter, it reverts to $10,000.
• The Act also contains phaseouts for those with modified adjusted gross income above $500,000.
• This $500,000 threshold increases by 1% per year from 2026 through 2029.
• There are no changes to the treatment of pass-through entity taxes.
• Consider AMT impact of increased itemized deduction for SALT.

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The Act

Campaign Promises

No Tax on Tips

• Individuals will get federal income tax deduction for qualified tips beginning from 2025 through 2028.
• Maximum deduction of $25,000.
• Tip exclusion will generally be limited to:
• The providing, delivering, or serving of food or beverages for consumption, if the tipping of employees delivering or serving food or beverages by customers is customary.
• Any of the following services if the tipping of employees providing such services is customary:
• Barbering and hair care.
• Nail care.
• Esthetics.
• Body and spa treatments.
• The Secretary of the Treasury will publish a list of other qualifying occupations.
• Deduction phases out for individuals with income over $150,000 ($300,000 for MFJ).

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The Act 

Campaign Promises

No Tax on Overtime

• Individuals will get federal income tax deduction for qualified overtime from 2025 through 2028.
• Only the portion exceeding regular hourly pay rate qualifies.
• Maximum deduction of $12,500 ($25,000 for MFJ).
• Qualified overtime does not include qualified tips.
• Deduction phases out for individuals with income over $150,000 ($300,000 for MFJ).

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The Act 

Campaign Promises

Senior Deduction

• Individuals 65 and older will get federal income tax deduction for 2025 through 2028.
• Maximum deduction of $6,000 ($12,000 for MFJ).
• Deduction phases out for individuals with income over $75,000 ($150,000 for MFJ).
• No benefit after income of $175,000 ($250,000 MFJ).

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The Act 

Campaign Promises

No Tax on Car Loan Interest

• Individuals will get federal income tax deduction for qualified interest paid on a new car loan for 2025 through 2028.
• Maximum deduction of $10,000.
• Must be a new car acquired after December 31, 2024.
• Final assembly of the car must have been in the United States.
• Deduction phases out for individuals with income starting at $100,000 ($200,000 for MFJ).
• Used cars do not qualify.

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The Act 

Campaign Promises

Trump Accounts

• Newly-created.
• Tax advantaged savings account for children born in the US between 1/1/2025 & 12/31/2028.
• Grow tax deferred until withdrawn (not permitted until child beneficiary obtains age 18).
• $1,000 one-time government contribution.
• $5,000 annual contribution limit in after-tax contributions.
• $2,500 may be contributed by employers per employee and excluded from employee gross income (applies towards $5,000 annual limit) pursuant to §128.

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The Act

Excess Business Losses

• Section 461(l) made permanent (originally scheduled to expire after 2028).
• Provides an annual limitation on net trade or business losses ($626,000 for married filing jointly in 2025 and $313,000 for all others). Losses in excess of that amount are carried forward as a NOL under current law.
• A simple example assuming only one trade or business. You would actually need to aggregate all trades or businesses:
• In 2025 I invest $5 million cash in a partnership/s corp and I am active in the business
• For 2025 I get a K-1 with a $1.6 million loss
• I get to deduct $600k in 2025
• The excess, $1 million, becomes a NOL on January 1, 2026 and it can offset up to 80% of my income in any future year and carries forward indefinitely

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Select Business Provisions

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The Act 

The “Big Three”

Bonus Depreciation

In general

• Act permanently reinstates 100% bonus deprecation for most tangible personal property acquired after January 19, 2025.
• Does not apply if a binding contract to acquire the property existed prior to January 20, 2025.
• Election to use reduced bonus depreciation percentage in first taxable year ending after January 19, 2025.

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Bonus deprecation on new production facilities

• New 100% bonus depreciation for nonresidential real property meeting certain requirements used in the manufacturing, production, or refining of tangible personal property.
• Applies to property if construction started after January 19, 2025, and before January 1, 2029, provided it is placed in service before January 1, 2031.
• Manufacturing defined by reference to “substantial transformation” test of Section 954(d).

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The Act

The “Big Three”

Section 174 Research Costs

• TCJA required capitalization and five-year amortization of domestic R&E expenses beginning in 2022.
• Under the Act, domestic R&E expenses are deductible when incurred for tax years beginning after December 31, 2024.
• Foreign R&E expenses continue to be capitalized and amortized over 15 years.
• Retroactive relief available:
• Small businesses (generally average gross receipts under $31 million under a controlled group test) would be able to file amended returns for 2022, 2023, and 2024 tax years to recover previously capitalized domestic research costs.
• All taxpayers have the option to deduct previously capitalized domestic research costs in first tax year beginning after December 31, 2024, or alternatively take the deduction over the first two tax years beginning after December 31, 2024.
• Returns Section 280C mechanics to pre TCJA status.

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The Act

The “Big Three”

Section 163(j) Business Interest Deduction

• Limitation currently based on 30% of tax basis EBIT.
• Act permanently increases the limitation to 30% of tax basis EBITDA.
• Change would be effective for tax years beginning after December 31, 2024.
• Redefines roles of Sec. 163(j)’s interest limitation provisions with certain interest capitalization provisions to give the Sec. 163(j) limitation priority. ​
• For tax years beginning after 2025, provides that Sec. 163(j) limitation is calculated prior to the application of any interest capitalization rules, except for interest capitalized under Sec. 263(g) or 263A(f). ​
• In so doing, certain ordering rules would require that you apply the Sec. 163(j) limit to amounts of interest which would be required to be capitalized and then any remainder would then be applied to amounts of interest that would be deducted. ​
• No portion of business interest carried forwards are to be treated as business interest expense to which an interest capitalization provision applies. ​

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The Act

Withholding Provisions

Increased threshold for 1099-MISC and 1099-NEC reporting.

• Raises reporting threshold from $600 to $2,000 for payments made after December 31, 2025.
• Makes conforming changes to backup withholding rules.
• The $2,000 threshold is indexed for inflation beginning in 2027.

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Select Credit & Other Provisions

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The Act

Select Credit & Other Provisions

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The Act

Select Credit & Other Provisions

Changes to Opportunity Zones after OBBBA

• Qualified Opportunity Zones were established to encourage investment in economically-distressed communities.
• Prior to OBBBA, the Opportunity Zone (OZ) program was set to sunset at the end of 2026.

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• Under OBBBA, the OZ program has been made permanent with additional favorable modifications.
• There is a rolling 10-year OZ designation beginning in 2027.
• There is no additional deferral for pre-2027 investments.
• There are enhanced benefits for rural OZs.
• For any investments after 2026:
• There is a fixed five-year deferral period.
• There is also a 10% basis step up.

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The Act

Opportunity Zone Example – Exit Strategy

Pre-OBBBA

• After hitting the 10-year mark (to qualify for tax-free appreciation), the investor faced a 2047 deadline to sell.
• If the investor didn’t sell by then, any further appreciation could be taxable.
• This constraint could have forced a sale of a still-thriving business or property just to lock in the benefit.

Post-OBBBA

• Under the new rules, the investor experiences full flexibility in exit timing. There is no mandatory sell-by date short of 30 years.
• The investor can keep holding the investment for 15, 20, even 25+ years, continuing to enjoy tax-free growth the entire time.
• Whenever the investor chooses to exit, they can step up their basis to market value and pay no capital gains tax on all the appreciation up to that point.
• If they hold the investment beyond 30 years, any additional growth after year 30 would be taxable.
• This change allows the investor to make business decisions based on market conditions or personal goals, not a tax deadline, which enables longer-term commitments to opportunity zone projects and potentially greater overall returns.

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How the changes to opportunity zones impact investors.

Facts: Investor holds an opportunity zone investment beyond 10 years.

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© 2025 Forvis Mazars, LLP. All rights reserved.

The Act

Select Credit & Other Provisions

Changes to Low Income Housing Tax Credits after OBBBA

• The Low Income Housing Tax Credit (LIHTC) program provides a federal tax credit to developers who build or rehabilitate rental housing for low-income households. These credits are claimed over a 10-year period.

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• Prior to OBBBA, there were two types of credits that were claimed over 10 years.
• 9% credit allocation – This was a competitive allocation for new construction or substantial rehabilitation.
• 4% credit allocation – This was a non-competitive allocation for projects financed with tax-exempt bonds.
• This credit had a 50% bond financing requirements.

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• Under OBBBA, the following changes have been made:
• There is a permanent 12.5% increase in the amount of tax credits available for the 9% competitive LIHTC credits.
• The bond financing requirements for the 4% credit allocation have been reduced to 25%
• The effective dates for LIHTCs are for buildings placed in service after 12/31/2025.

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The Act

Select Credit & Other Provisions

Changes to New Markets Tax Credits after OBBBA

• New Markets Tax Credits program is a federal development program which attracts private investment to distressed communities.
• The NMTC program is administered by the CDFI Fund, which is a division of the Department of Treasury.
• Community projects should view the NMTC program as a project financing tool.
• The NMTC program offers a 39% federal tax credit over 7 years to investors who make equity investments in Community Development Entities (CDEs).
• The NMTC program was extended and made permanent with OBBBA.

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• NMTC program opportunities include:
• Is the project in an underserved state? KS is currently designated as an underserved state.
• Can the project spend the NMTC funds received within 12 – 18 months?
• Is the project cost at least $4M? The “sweet spot” for allocation is between $5 - $15M, but projects may be larger.

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© 2025 Forvis Mazars, LLP. All rights reserved.

The Act 

Select Credit & Other Provisions

Credits Terminated

Sections 25E, 30D, and 45W.

• Clean vehicle credits for new and used vehicles terminated if acquired after 9/30/2025.

Section 30C.

• Alternative fuel vehicle refueling property credit terminated for property placed in service after 6/30/26.

Section 25C and 25D.

• Home credits for energy efficient terminated for property placed in service after 12/31/25.

Section 179D.

• Deduction (not technically a credit) is also terminated for properties that begin construction after June 30, 2026.

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The Act 

Select Credit & Other Provisions

Section 45Y (Production Tax Credit) / Section 48E (Investment Tax Credit)

Solar and wind projects

• Projects that begin construction before 7/5/26 must be placed in service by 12/31/30.
• Projects that begin construction after 7/4/26 must be placed in service by 12/31/27​.

Other clean energy projects (e.g., biogas, waste energy recovery) eligible for credits longer

• Construction must begin before 1/1/34 to claim full credit.
• Phase down of credit in 2034 and 2035 with complete elimination in 2036.

Section 45X –Advanced manufacturing production credit

• Wind/solar components produced and sold after 12/31/27 not eligible.
• Phaseout for critical minerals begins in 2031
• Metallurgical coal added to the list

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Emily Howell

Director

P: 316.854.4424

emily.howell@us.forvismazars.com

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Ashley Mapel

Director

P: 316.768.5186

ashley.mapel@us.forvismazars.com

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Contact

Forvis Mazars

The information set forth in this presentation contains the analysis and conclusions of the author(s) based upon his/her/their research and analysis of industry information and legal authorities. Such analysis and conclusions should not be deemed opinions or conclusions by Forvis Mazars or the author(s) as to any individual situation as situations are fact-specific. The reader should perform their own analysis and form their own conclusions regarding any specific situation. Further, the author(s)’ conclusions may be revised without notice with �or without changes in industry information and legal authorities.

© 2025 Forvis Mazars, LLP. All rights reserved.

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© 2025 Forvis Mazars, LLP. All rights reserved.