The One Big Beautiful Bill Act restores immediate expensing for tax years beginning in 2025, and creates a one-time refund window for small businesses.
OBBBA's accelerated termination of several IRA energy credits produced a fourth-quarter scramble. October through December 2025 was three months of urgent placed-in-service deadlines and last-minute project acceleration.
The fourth quarter of 2025 produced more IRS administrative guidance than any comparable period in recent tax history: at least 23 notices and 4 revenue procedures specifically implementing OBBBA. Here is the catalog.
ARPA's enhanced PTC expired. The 400% FPL subsidy cliff returned January 1, 2026. Self-employed and early-retiree clients face material 2026 affordability shock.
Three years after the EBIT change made the business-interest limitation more painful, OBBBA puts EBITDA back in the calculation. Real estate and capital-intensive businesses are the obvious winners.
FLPs remain valuable for $15M–$50M estates. Connelly v. United States (2024) restructured buy-sell math. The Strangi/Bongard/Kimbell line still defines defensible structure.
With OBBBA's $15M permanent exemption, the estate-tax-avoidance Roth case fades for many. The income-tax-bracket arbitrage remains. SECURE 10-year payout still drives conversion before death.
Treasury's November 2023 DAF proposed regs are still not final. The OBBBA 0.5% charitable floor and SECURE 2.0 §307's one-time $54K split-interest QCD change the optimization.
After-tax 401(k) contributions converted to Roth. SECURE 2.0 §603 Roth catch-up for $150K+ FICA earners now effective January 1, 2026 after two years of transition relief.
Treasury's interim guidance on the Corporate Alternative Minimum Tax narrows financial-statement income in ways that matter for mid-market private companies.
VDP for willful conduct. 75% civil fraud penalty on the highest-tax year. Criminal protection contingent on full, truthful disclosure. Kovel arrangements preserve attorney-client privilege.
SECURE 2.0 §605 codified the 2.5x cap. The Tax Court continues to disallow syndicated deductions with 40–75% penalties. Mill Road 21 and Hewitt extended the precedent. Legitimate easements still work.
SFOP for non-residents (0% penalty), SDOP for U.S. residents (5% penalty). Non-willful certification is the determining factor. Form 14653 / Form 14654, false certification is itself a §7206 violation.
Authorized under 6 Del. C. §18-215 since 1996. Tax treatment unresolved (proposed regs from 2010 never finalized). Inter-series shield untested in most non-series-LLC states.
OBBBA repealed the ARPA $600 threshold retroactive to 2022. The pre-ARPA standard ($20,000 gross AND 200 transactions) is now permanent.
The March 26 interim final rule narrowed the Corporate Transparency Act to foreign-formed entities only, but state-level reporting just got more important.
Treasury's final regulations (TD 10000) introduce Form 1099-DA for reporting beginning in 2026.
Ohio raised its CAT exclusion to $3M (2024) then $6M (2025), exempting roughly 90% of filers. The tax is now a top-of-market levy on businesses above $6M of Ohio gross receipts.
5.5% on Florida net income, single-sales-factor apportionment as of 2024, $50K standard exemption, R&D credit at 10% of QREs above prior-4-year-average. S corporations and partnerships fully exempt.
AK, FL, NV, NH, SD, TN, TX, WA, WY. Domicile is intent + presence. Statutory residence is the 183-day trap. Washington has a capital gains tax. New Hampshire just finished phasing out its I&D tax.
Hochul's December 19 veto leaves the NYLTA aligned with the post-March 2025 federal CTA, applying only to non-U.S. LLCs.
Luxury Advisory. Precision Compliance. Quarterly correspondence from our partners on tax, structure, and stewardship.