One Big Beautiful Bill for Business

Jeremy Springer
Oct 6
3 min read

Congress signed the “One Big Beautiful Bill Act” into law on July 4, 2025. The law reshapes several business-tax rules that will show up in the 2025 filing season and beyond. Here’s a plain-English walkthrough for common business return types—what changed, why it matters, and what to consider before you file.

If You File Form 1120 (C-Corporations)

Faster write-offs for new equipment. The law lifts the Section 179 expensing ceiling and raises the phase-out threshold for property placed in service after December 31, 2024. That means more purchases can be expensed up front rather than depreciated over years—improving cash flow in 2025.
Bonus depreciation and real property. Full (100%) bonus depreciation returns and certain nonresidential real-property improvements get more favorable cost recovery. For asset-heavy companies, this can tip capital projects from “maybe” to “go.”
Interest deductions recalibrated. The Section 163(j) limit is reworked around a taxable-EBITDA measure starting with tax years after 2024, generally allowing larger interest write-offs, with additional technical changes after 2025. Model the rules before refinancing or pushing leverage.
Cross-border items updated. Deductions tied to foreign income are reset for years beginning after 2025, affecting the effective rates on income from controlled foreign corporations and exports; the BEAT minimum tax is set at 10.5% rather than rising further. Global groups should revisit entity and supply-chain structures.
Quick cash from prior-year changes. If new 2025 deductions generate carrybacks, C-corps can request a fast refund using Form 1139 (filed separately from the return).

If You File Form 1120-S (S-Corporations) or a Partnership Return

Pass-through deduction made durable. The 20% qualified business income (QBI) deduction is made permanent and the income thresholds are updated, which can preserve a sizable deduction for many owners—subject to existing limits and wage/property tests. Coordinate salary vs. distribution decisions with care.
Bigger up-front expensing. S-corps and partnerships benefit from the same Section 179 expansion and renewed bonus depreciation as C-Corps, which can reduce owners’ current-year pass-through income. Keep an eye on basis and at-risk limits to actually use the losses.
QSBS gets more attractive—if you’re a C-Corp convert. While S-Corps don’t issue QSBS, some growing firms consider converting to C-Corp status to court investors. The law widens who can issue QSBS and introduces tiered gain exclusions for shares acquired after July 4, 2025; plan ahead if fundraising is on your horizon.

If You Use Form 1045 (Tentative Refund) After a Bad Year

Form 1045 is a quick-refund tool for individuals, estates, and trusts—not corporations. It speeds refunds from NOL or credit carrybacks when a business owner’s personal return is the place those losses land (for example, sole proprietors or pass-through owners). Corporations use Form 1139 instead.

Because the law front-loads more deductions into 2025 (through expensing and bonus depreciation), some owners will see larger pass-through losses. If those losses can be carried back under current rules and you qualify, 1045 can accelerate cash back into the business. (Check the one-year filing window and interaction with other elections.)

Other Situations to Watch

Capital projects. The combination of expanded Section 179 and restored bonus depreciation can change the math on vehicles, machinery, software, and certain nonresidential improvements put in service after 2024. Line up documentation—purchase agreements, placed-in-service dates, and asset classifications—so your deduction is bullet-proof.
Debt planning. The new 163(j) framework makes interest capacity a moving target between 2025 and 2026. If you’re negotiating a credit line, run side-by-side projections under both sets of rules to avoid surprises.
International footprints. With revised deduction percentages and renamed regimes for foreign-source income, multinationals should update their effective tax-rate models and revisit where IP and functions reside. The BEAT rate change also affects payments to related foreign parties.

What to Do Now

Update 2025 forecasts to reflect larger up-front deductions and any interest-expense changes.
Review entity structure if you’re contemplating outside investment; post-July-2025 QSBS rules may influence timing.
Prepare carryback playbooks (Form 1139 for C-corps; Form 1045 for individuals/estates/trusts) so you can move quickly if the year ends in a loss.

Still note sure where to start? Reach out to our office so one of our trust tax pros can help you find the best tax strategy for your company in 2025 and beyond.

Legal Disclaimer: This post contains general information for taxpayers and should not be relied upon as the only source of authority. Taxpayers should seek professional tax advice for more information. This information was current at time of posting; we are not responsible for updating this or any blog post/article for subsequent changes in the law or its interpretation.