Dive into H.R. 1, commonly referred to as OBBBA, business tax provisions, and planning imperatives in this session of the H.R. 1 Tax Masterclass Series.
We begin with: Research and development (R&D) expensing under Sec. 174, including amendments, retroactivity, and small business election Cost segregation/qualified production property (QPP)
Next, we'll lock in on: Qualified business income (QBI) benefits Temporary state and local tax (SALT) cap boost Passthrough entity (PTE) workarounds
Industry experts will share insights on: Real estate (mortgage, Opportunity Zones (OZs), Sec. 179D), Manufacturing (bonus/production property) and construction
We will talk about the M&A provisions and an entity choice module, expanding on qualified small business stock (QSBS) tiers, OZ permanence, and leverage considerations.
We’ll touch on: The revived employee retention credit (ERC) and employer benefits planning Energy incentives Mapping timelines Documentation requirements State/ESG alternatives
Learning Objectives
- Apply Sec. 174 retroactivity rules and small business elections to research budgets to optimize R&D expensing.
- Distinguish QBI safe harbor strategies and model SALT cap/PTE workarounds across states.
- Use actionable strategies for real estate, manufacturing, and construction clients, leveraging mortgage/OZ incentives, Sec. 179D deductions, and bonus depreciation timing.
- Compare QSBS tiers, OZ permanence, and entity-based leverage for tax efficiency for M&A entities.
- Identify ERC eligibility and design Trump EE comp agreements ahead of Sec. 274(o) to revive ERC and comp plans.
- Determine incentive deadlines, satisfy documentation rules for Sec. 179D, and integrate ESG alternatives to leverage energy incentives.
Major Topics
R&D / Sec. 174 / Cost Segregation / QPP QBI SALT — Temporary cap increase, PTE workarounds, and state conformity updates Industry specific highlights M&A provisions and entity choice ERC and new planning considerations Energy incentives
