Successful manufacturers have the ability to navigate various
changes, whether positive or negative. On the positive side, potentially, are
tax law changes enacted under the One, Big, Beautiful Bill Act (OBBBA). Perhaps
the most important changes for manufacturers are the OBBBA's liberalized rules
for depreciating business assets. Let's take a closer look at a few tax-related
provisions that may be most consequential to your manufacturing company.
Depreciation-related breaks
Many provisions in the sweeping Tax Cuts and Jobs Act (TCJA) had
been set to expire soon or had already expired. Among them was 100% first-year
bonus depreciation.
Under the TCJA, manufacturers could claim bonus depreciation on
purchases of assets such as new or used machinery, equipment and computer
systems. Manufacturers could deduct 100% of the purchase price of qualified
property placed in service beginning September 28, 2017, through 2022. But
the first-year bonus depreciation percentage had dropped to 40% for 2025 and
was scheduled to decrease to 20% for 2026 and 0% for 2027. The OBBBA makes
permanent 100% first-year bonus depreciation for the cost of qualified assets
acquired and placed in service after January 19, 2025.
The OBBBA also increases the Section 179 expensing limit.
For qualifying property placed in service in 2025, the OBBBA doubles the
expensing limit to $2.5 million. The break begins to phase out
dollar-for-dollar when asset acquisitions for the year exceed $4 million
(up from $3.13 million before the OBBBA). These amounts will continue to
be annually adjusted for inflation after 2025.
Sec. 179 expensing allows manufacturers to deduct (rather than
depreciate over a number of years) the cost of purchasing eligible new or used
assets, such as equipment, furniture, off-the-shelf computer software and
qualified improvement property (QIP), placed in service during the tax year.
(QIP includes improvements to interior portions of nonresidential real estate.)
Finally, the OBBBA creates a new deduction for qualified
production property. The deduction is 100% and generally applies to
nonresidential real property used in manufacturing that's placed in service
after July 4, 2025, and before 2031.
Together, these depreciation changes are expected to encourage
capital investments, especially by manufacturing companies. And the permanent
100% bonus depreciation may alleviate the pressure on companies that didn't
want to delay purchases due to a smaller deduction.
Research and experimentation expense
deduction
Beginning in 2022, the TCJA required businesses to amortize
Sec. 174 research and experimentation (R&E) costs over five years if
incurred in the United States or 15 years if incurred outside the country. With
the mandatory mid-year convention, deductions were spread out over six years.
The OBBBA permanently allows the deduction of domestic R&E expenses in the year
incurred, starting with the 2025 tax year.
In addition, the OBBBA allows "small businesses" to file amended
returns to claim the deduction retroactively for 2022 through 2025. Regardless
of size, businesses that incurred domestic R&E expenses in 2022 through
2024 can elect to accelerate the remaining deductions for those expenditures
over a one- or two-year period, rather than amortizing them over the full
five-year period.
Qualified business income deduction
The Sec. 199A deduction for qualified business income (QBI) for
owners of pass-through entities (such as partnerships, limited liability
companies and S corporations) and sole proprietorships was slated to
expire after 2025, putting many manufacturing business owners at risk of higher
taxes.
The OBBBA makes the QBI deduction permanent. It also expands the
income phase-in ranges for the wage and investment limitation, which limits the
QBI deduction amount to:
- 50% of the
amount of W-2 wages paid to employees by the qualified business during the
tax year, or
- The sum of 25%
of W-2 wages plus 2.5% of the cost (not reduced by depreciation taken) of
qualified property, which is the depreciable tangible property (including
real estate) owned by a qualified business as of year-end and used by the
business at any point during the tax year to produce QBI.
The limitation begins to apply when the taxpayer's taxable
income falls within the phase-in range and fully applies when taxable income
exceeds the range. For 2025, the phase-in range is $197,300-$247,300
($394,600-$494,600 for married couples filing jointly). The new law expands the
phase-in range from $50,000 to $75,000 (from $100,000 to $150,000 for joint
filers) beginning in 2026.
Turn to us with questions
These are just a few of the many business-related tax provisions
of the OBBBA. Contact us to learn more about how your manufacturing company can
take advantage of the new law's tax breaks and incentives.