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Inside the first 100 days: How a sweeping tax bill is prompting new moves on capital, structure, and strategy
Consumer markets companies are accustomed to operating at speed. They sit at the center of evolving consumer expectations, cultural shifts, and competitive pressure—and often lead the way on innovation. But in a business environment shaped by volatility, tax policy has remained one of the hardest variables to plan around.
That may be starting to change. Since the One Big Beautiful Bill (OB3) was signed into law on July 4, 2025, business leaders in the sector are reassessing how and where to act. Unlike past tax reforms, OB3 introduced a level of permanence around key provisions like interest deductibility and accelerated depreciation. That stability is prompting companies to revisit capital allocation, rethink structural decisions, and accelerate long-delayed moves.
To understand how that’s playing out behind the scenes, we spoke with Megan Herzog, PwC’s US consumer markets tax sector leader, and Doug Skorny, an M&A tax partner focused on M&A in the consumer sector. We talked about what’s different this time, how OB3 fits into broader strategic planning, and what to watch in the months ahead.
The following is an edited version of the conversation.
Q: What’s the biggest shift since OB3 became law?
Megan Herzog: The permanency of certain provisions is a big deal. For the first time in decades, companies aren’t reacting to temporary changes. They can plan with greater confidence. That’s freeing up cash flow, especially in consumer markets, and we’re seeing many leaders considering how to redeploy that capital into the business.
Doug Skorny: The US is a more competitive tax jurisdiction. Combined with the permanent deduction and amortization rules for asset purchases, accelerated R&D deductions, and favorable foreign royalty and license income flows, companies are reinvesting—building factories, evaluating deals, and in some cases repatriating intellectual property. That’s a meaningful shift.
“The permanency of certain provisions is a big deal. For the first time in decades, companies aren’t reacting to temporary changes.”
Megan Herzog,Consumer Markets Tax Leader, PwC USQ: Why are companies acting faster than they did after past reforms?
Herzog: The guidance is more familiar. OB3 builds on and in some cases reenacts tax legislation that has been in place historically, which allows companies to interpret and apply it faster. That’s a big contrast to the post-2017 environment, where uncertainty slowed decision-making.
Skorny: The market context also matters. There’s already strong momentum around deals in the consumer markets sector. OB3 isn’t the only driver, but it’s helping to reduce friction. Companies that were waiting for clarity are now executing.
"There’s already strong momentum around deals in the consumer markets sector. OB3 isn’t the only driver, but it’s helping to reduce friction."
Doug Skorny,Merger & Acquisition Tax Partner, PwC USQ: What surprised you most in the first 100 days?
Herzog: In the past, there was a lot of theoretical conversation about repatriating or shifting value chains—but little action. Now, we’re seeing many companies seriously evaluating their business footprints.
Skorny: I’d add that OB3’s interplay with global tax rules like Pillar Two was a surprise relative to earlier versions of draft legislation. The final legislation alleviated some concerns for US multinationals, creating a clearer path forward.
Q: What kinds of strategic decisions are happening now?
Herzog: On the structuring side, we’re seeing increased interest in moving operations. These are foundational changes that reflect a level of confidence we haven’t seen in a while.
Skorny: On the investment side, the math has changed. Provisions like bonus depreciation and interest deductibility shift return calculations. Suddenly a capital project or M&A deal may clear the internal rate of return hurdle. For all investors, including private equity firms, that’s meaningful.
Q: Could consumers feel any of this downstream?
Herzog: It’s still early, but there’s potential. In the spring, companies were navigating both tariff uncertainty and the tax landscape. OB3 took one of those unknowns off the table. That doesn’t mean prices will change overnight, but it could influence long-term cost structures and investment in consumer-facing capabilities.
Skorny: It’s about optionality. OB3 gives companies room to modernize systems, invest in AI, or test new product lines. That kind of flexibility can ultimately benefit consumers.
Q: Any risks leaders should be aware of?
Herzog: I’d say one is the corporate alternative minimum tax (CAMT). Some companies are finding that, ironically, too many “good” outcomes under OB3 could push them into a different tax posture under CAMT, which is based on financial statement income. That’s new territory for many.
Skorny: It’s important to model carefully. Changes in certain perceived taxpayer-favorable provisions can have ripple effects on other reporting and compliance obligations such as the corporate alternative minimum tax or CAMT.
Q: How are companies using AI to navigate these changes?
Herzog: AI isn’t replacing tax modeling, but it is helping companies move faster. We’re seeing teams using agents to gather inputs, run scenarios, and test assumptions in real time. It’s part of a broader shift toward faster, more iterative planning.
Skorny: It’s also influencing workforce strategy. Companies are asking: What skills will we need as AI becomes more embedded? What does a future-ready tax team actually look like? That’s still evolving, and it varies by business model. Every company is defining that for themselves.
Q: Any final advice for leaders in consumer markets?
Herzog: Don’t wait. This is a window of opportunity. Companies that embed their tax strategy into their strategic business imperatives—before the next wave of changes—can have more room to maneuver later.
Skorny: And make sure your models are telling the full story. OB3 may open new doors, but the downstream implications—on compliance, structure, and ROI—still need to be mapped with care.
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