Insights from America in motion

Translating the tax bill for business: How should executives prepare?

  • August 14, 2025

As tax provisions in the One Big Beautiful Bill Act begin to take effect, it’s time to reassess strategy—and not just tax strategy. The bill’s implications cut across enterprise, posing both risks and opportunities. Determining the right path forward depends on an integrated approach to business planning.

By making permanent several provisions of the Tax Cuts and Jobs Act that were due to expire this year, the legislation offers some degree of clarity and stability for businesses in years to come. It incentivizes capital investment in the United States but, at the same time, it significantly alters the outlook for clean energy tax credits established under the Inflation Reduction Act. The final version also eliminated a proposed retaliatory tax on certain foreign corporations and investors, following a G7 agreement on global minimum taxes. Note, however, that the G7 agreement still requires individual countries to pass legislation to exempt US businesses from Pillar Two rules, and it doesn't address tax provisions in countries outside the G7.

Ultimately, OBBBA incorporates many changes to the US tax code that require nuanced interpretation, particularly given their interconnected effects. While tax teams sift through the technical details, you can start asking the right questions to shape broader strategy.

We get it. It’s complex, but opportunity lies with those who can unlock it. Staying ahead of regulatory changes—particularly if your company engages in cross-border activity or conducts business in certain tax jurisdictions—can help prevent costly missteps and create value. Here are four key areas where the bill’s tax provisions may make a difference.

The legislation incentivizes domestic investment, in part through rules allowing for immediate expensing for certain assets as well as research and development activities. Factor these incentives into your strategic planning for innovation and growth. Develop a strategy for evaluating your global footprint and consider whether it makes sense to expand in the US, realign across jurisdictions or stay where you are.

Questions to consider: Where does your company want to grow—and how will it grow? How will the tax bill affect strategic projects?

Tariffs have already spurred companies to absorb costs or pass them on, and OBBBA offers another reason to consider whether new strategies are necessary. In particular, evaluate your intellectual property, where it's located and how it’s used. IP raises many tax issues, including transfer pricing, so be proactive in determining whether IP and trade flows need to shift.

Questions to consider: Where should your company do business? How do you deliver? What does OBBBA mean for your IP—and would making changes introduce other issues or create opportunities?

You can now make better decisions around financing projects. OBBBA offers expensing as well as clarity around how much interest is deductible for US tax purposes. With this information, you can determine which jurisdictions might offer easier access to cash or more beneficial terms for borrowing.

Questions to consider: Where does your company borrow for investments? Would it be better to borrow in another jurisdiction, due to potential interest deductions?

More than a dozen clean energy credits established by the Inflation Reduction Act have been affected by the new legislation. New phase-outs, sunset dates, rates and qualification criteria should inspire leaders to accelerate or rethink investments that are already in flight. It may be possible to reduce or offset costs through other means—perhaps by buying credits on the market in other areas. Loans may also be necessary. While the incentives may not be as robust as they were under the IRA, some still remain, including prevailing wage and apprenticeship credits. Be pragmatic in working to advance what will continue to be a global strategic initiative.

Questions to consider: How will your company approach sustainability projects that are already underway or planned? Is it possible to pivot? Are there other options to reduce the cost of capital?

Executives across your enterprise should consider how this new legislation affects overall strategy. Ask your business leaders whether they’ve considered the tax benefits and risks of their planned investments. Have your tax teams run the numbers and then collaborate. Working together, the risks and opportunities will become apparent, allowing your company to pivot for success. Proactivity with OBBBA doesn’t just save taxes, it can be a pathway to super charge growth and build more predictable and resilient businesses to deliver sustained shareholder value.

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Anna  Green

Anna Green

Lead Tax Partner, PwC US

Michelle Horton

Michelle Horton

Principal, Health Industries Risk and Regulatory Leader, America in Motion leader, PwC US

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