- Expansion and permanence of important business tax benefits such as deductions for qualified small business stock (QSBS), research and experimentation costs, and reduced limitations on business interest deductions. These changes encourage investment and business growth.
- Important changes to international tax rules affecting U.S. companies with foreign operations, including significant reductions in the number of foreign corporations that are treated as controlled foreign corporations (CFC), and favorable modifications to the pro rata share rules affecting US shareholders in CFC.
- Extension and modification of energy tax incentives impacting businesses involved in renewable energy and energy storage.
- Enhanced incentives for Qualified Opportunity Zones and increased benefits for business owners investing in small businesses, including holding period reductions and elevated exemption limits on capital gains.
- Increased estate, gift, and generation-skipping tax exemption amounts providing high-net-worth business owners with greater estate planning flexibility and wealth transfer opportunities.
- Modifications to state and local tax (SALT) deduction limits, and preservation of workarounds useful for pass-through entities, helping reduce state-level tax burdens for businesses, especially family offices and partnerships.
Overall, from a business standpoint, the Act provides a stable and business-friendly tax framework by solidifying popular TCJA provisions, introducing new incentives to stimulate investment and growth, and offering expanded tax planning opportunities. However, it also includes some revenue-raising measures, such as limits on certain deductions and adjustments to credits, to partially offset its cost. Businesses are advised to carefully analyze the Act’s broad and complex provisions to optimize tax planning and compliance under the new law.