Insights

USA: Initial Takeaways on the House’s "Big Beautiful Bill" and Implications for M&A and Business Tax Strategy

Editorial Team 13 Jun 2025

An analysis by Leo Berwick, Taxand USA

The U.S. House of Representatives has recently passed the “One Big Beautiful Bill Act” by a narrow margin, proposing major changes to business-related tax provisions. The Bill, now with the Senate, could have significant implications for M&A, private equity, and foreign investment strategies. Experts from our US member firm Leo Berwick have shared their initial analysis, highlighting key provisions which include:

• Interest Deduction (163j): Returns to EBITDA basis, boosting deductibility for leveraged deals.
• Bonus Depreciation: Restores 100% first-year write-offs for assets placed in service from Jan 2025 to Jan 2031.
• R&D Expensing: Allows immediate deduction of domestic R&D costs through 2030.
• SALT Cap: Raises the cap to $40,000 but limits pass-through workarounds for high-income service professionals.
• 199A Deduction: Expands deduction to 23% and broadens eligibility for pass-through businesses.
• New §899: Imposes higher U.S. tax on income from “discriminatory” foreign countries, potentially deterring inbound investment.
• BEAT Changes: Tightens rules on foreign-owned multinationals, though portfolio interest exemptions remain viable.

If enacted, the bill would lower U.S. tax burdens for capital-intensive and R&D-heavy businesses but complicate cross-border investment structures. You can read the full analysis in further detail here.

Article tags

BEPS | Corporation Tax | Cross border | M&A Tax | Tax Policy | Tax Reform | USA