REGULATORY, POLICY AND TAX CHANGES FOR 2025

The OBBB permanently reinstates 100% expensing (using bonus depreciation) to fully deduct the cost of qualified property acquired beginning January 20, 2025. Additionally, the OBBB expands the scope of “qualified assets” to cover manufacturing buildings beginning January 20, 2025.

Under the TCJA, the effective rate on GILTI was set to rise from 10.5% to 13.125% and on FDII from 13.125% to 16.406%, both in 2026. Under the OBBB, taxpayers subject to GILTI and FDII will see their Section 250 deduction reduced, thereby raising their respective effective U.S. tax rates to approximately 14%.

The OBBB allows for a permanent reinstatement of immediate expensing for domestic R&D expenditures, which reverses the TCJA’s five-year amortization requirement. It also provides for retroactive relief (2022-2024) for businesses with average annual gross receipts under $31 million.

The OBBB will grant the oil, gas, geothermal and coal industries expanded access to federal lands and resources. The text includes sections that will streamline leasing processes, lower regulatory barriers and offer additional financial incentives.

The OBBB accelerates the expiration of multiple clean energy tax credits from their original 2032 end date to much earlier dates in 2025 or 2026. This includes clean electricity (Sections 45Y and 48E), energy efficient homes and commercial buildings (Sections 25D, 25C, 45L and 179D), and clean vehicles (Sections 25E, 30C, 30D and 45W).

Beginning in 2026, the OBBB will permanently raise the federal estate, gift and GST exemptions to $15 million per individual and $30 million for married couples. The new law also makes annual adjustments for inflation that start in 2027.

The One Big Beautiful Bill Act contains major tax provisions impacting individuals, including individual income tax rates, standard deductions, the qualified business income deduction, auto loan interest, the child tax credit, the SALT deduction cap, Section 1202 amendments, HAS contribution limits and more. Explore the full impact here.

We help you understand whether the right codes are being used and what the tariff impact will be on your business. We also develop a process of tracking movement with each new tariff decision.

Make sure you’re correctly navigating the USMCA agreement and compliance. Wipfli brings the right information to the table, including evaluating your specific products and the impact on them.

Wipfli can help you understand the strategic implications of reshoring and identify new opportunities, find new sources for your parts in the U.S. or North American markets, and navigate the impact of tariffs on automation equipment and machinery.

We help you develop tariff tracking mechanisms and scenario planning exercises, support financial modeling for each critical purchasing decision, and determine the impact of new and future tariffs on your financial statements.

Wipfli helps determine which states subject the tariff portion of a good or part to sales and use tax and how tariffs will impact your profitability in each filing jurisdiction. We produce a bridge analysis between IRS transfer pricing methods/requirements and U.S. Customs transfer pricing valuation methods. Through it, you can determine the appropriate arm’s length price for intercompany sales acceptable to both IRS and CBP.

We can analyze options for unbundling the dutiable value of goods, which improves customs and TP compliance by helping ensure duties are not paid on non-dutiable elements and supports accurate functional segmentation and benchmarking. Wipfli can also help evaluate other methods of accounting, such as LIFO, to assess potential tax savings.

We can help you develop a sales process framework to capitalize on reshoring and identify opportunities, both within the U.S. and internationally, as part of strategic planning. Our sales process team can also help augment your sales team to strategize how the tariffs can work in favor of your business.

Wipfli’s automotive team works with you to navigate challenges and develop the right strategies for your business. Our team provides clear guidance to help ensure compliance with USMCA regulations and can work with you in a consultative approach to navigate tariff, trade and supply chain problems.