H.R. 1 and the Road Ahead: Emerging Business Tax Considerations

Overview

Dive into H.R.?1, commonly referred to as OBBBA, business tax provisions, and planning imperatives in this session of the H.R. 1 Tax Masterclass Series. 

We begin with:

• Research and development (R&D) expensing under Sec.?174, including amendments, retroactivity, and small business election
• Cost segregation/qualified production property (QPP) 

Next, we'll lock in on:

• Qualified business income (QBI) benefits
• Temporary state and local tax (SALT) cap boost
• Passthrough entity (PTE) workarounds 

Industry experts will share insights on:

• Real estate (mortgage, Opportunity Zones (OZs), Sec. 179D)
• Manufacturing (bonus/production property) and construction

We will talk about the M&A provisions and an entity choice module, expanding on qualified small business stock (QSBS) tiers, OZ permanence, and leverage considerations. 

We'll touch on:

• The revived employee retention credit (ERC) and employer benefits planning 
• Energy incentives
• Mapping timelines
• Documentation requirements
• State/ESG alternatives

Prerequisites

Fundamental knowledge of the new H.R. 1 tax bill, commonly referred to as OBBBA.

Objectives

• Apply Sec.?174 retroactivity rules and small business elections to research budgets to optimize R&D expensing.
• Distinguish QBI safe harbor strategies and model SALT cap/PTE workarounds across states.
• Use actionable strategies for real estate, manufacturing, and construction clients, leveraging mortgage/OZ incentives, Sec. 179D deductions, and bonus depreciation timing.
• Compare QSBS tiers, OZ permanence, and entity-based leverage for tax efficiency for M&A entities.
• Identify ERC eligibility and design Trump EE comp agreements ahead of Sec.?274(o) to revive ERC and comp plans.
• Determine incentive deadlines, satisfy documentation rules for Sec. 179D, and integrate ESG alternatives to leverage energy incentives.

Highlights

• R&D / Sec. 174 / Cost Segregation / QPP
• QBI
• SALT — Temporary cap increase, PTE workarounds, and state conformity updates
• Industry specific highlights
• M&A provisions and entity choice
• ERC and new planning considerations
• Energy incentives