One Big Beautiful Bill Act: Tax Changes to Domestic and Global Business

The One Big Beautiful Bill Act (OBBB), signed into law on July 4, 2025, introduced significant changes to the U.S. tax code. The OBBB contains a host of tax provisions designed to incentivize domestic operations and refine and redesign international tax provisions. The OBBB will significantly impact businesses, tax professionals and stakeholders operating in today's dynamic global economy. Please join Holland & Knight attorneys for a discussion on the central features of the OBBB, with a particular focus on two critical areas: domestic business income and international tax provisions.

The OBBB has sparked important conversations in boardrooms, legal circles and accounting firms alike. As organizations strive to understand, interpret and comply with its multifaceted requirements, our webinar will provide an authoritative overview of the significant changes, implications, opportunities and pitfalls embedded within the OBBB's domestic provisions applicable to business income, as well as the international provisions applicable to cross-border transactions.

Our panelists will also explore how these federal changes will interact with existing state and municipal tax frameworks. You will gain insight into both the legislative philosophy and the practical realities businesses will face as the new rules take effect.

We hope you can join us for this highly informative presentation. There will be ample time to ask questions.

Topics

Domestic Business Income: Encouraging U.S. Investment

• enhanced 20 percent deduction for qualified business income
• expanded benefits for qualified small business stock
• improved incentives for qualified opportunity zones
• increased deductibility of business interest
• reinstated full expensing for research and experimentation costs
• immediate and enhanced full expensing for qualifying equipment and software
• the restoration and expansion of bonus depreciation
• a new elective, temporary provision that provides 100 percent expensing of certain nonresidential real property used in a qualified production activity

International Tax Provisions

• dropping the so-called "Revenge Tax" and the "G7 side-by-side agreement" on the global minimum tax
• changes to global intangible low-taxed income (GILTI) (renamed Net CFC Tested Income (NCTI))
• changes and opportunities related to the revised foreign-derived intangible income (FDII) (renamed Foreign-Derived Deduction Eligible Income)
• Base Erosion and Anti-Abuse Tax (BEAT)
• new foreign tax credit source of income rule for U.S.-produced property sold through a branch abroad
• refinements to the CFC provisions: CFC taxable year, pro rata rule, look-through rule and revisions to constructive downward attribution rules
• new remittance tax
• an unexpected benefit: How the estates of foreign decedents can claim a portion of the lifetime estate tax exemption to minimize the U.S. estate tax

Speakers

Michael Karlin | Partner, Century City
Jennifer Karpchuk | Partner, Philadelphia
Joshua Odintz | Partner, Washington, D.C.
Andrew Siracuse | Partner, Washington D.C.
Alan Granwell | Of Counsel, Washington, D.C.
Bryan Marcelino | Senior Counsel, Washington, D.C.

Continuing Legal Education (CLE)

Please note: After completion of the program, Holland & Knight (and its CLE administration partner, CEU Institute) will apply for CLE credit based on attendee requests. Some programs may not be awarded CLE credits because of content or jurisdictional restrictions. Please be aware that the CLE approval process can be lengthy in some jurisdictions. Holland & Knight is an approved CLE provider in several jurisdictions, including California, Illinois, New York, Pennsylvania and Texas. For New York attorneys, this program's format qualifies for CLE for transitional (newly admitted) and experienced attorneys.