Section 174: R&D Expensing Clarity and Retroactivity
The Senate version confirms what many hoped for: a full suspension of R&D amortization. Notably, the provision also includes retroactive application—a significant detail for companies that have already begun planning under the amortization rules. This would allow for immediate expensing of R&D costs, easing financial burdens and encouraging near-term innovation investments.
Bonus Depreciation: Holding at 100%
Echoing business priorities, the draft bill restores 100% bonus depreciation—a reversal of the phase-down path currently in place. If passed, this would enable companies to continue front-loading deductions on qualifying assets through at least 2027.
Business Interest: EBITDA Returns, For Now
The bill proposes a temporary return to an EBITDA-based interest deduction limit under Section 163(j), shifting back from the more restrictive EBIT-based framework. This change may provide short-term relief to capital-intensive sectors while a more permanent approach is developed.
Nonprofits: Tax Complexity Grows
The nonprofit sector faces renewed complexity.
- Excise tax on investment income could rise substantially for institutions with $2M+ in endowment per student, although the top rate has dropped from 21% in the House version to 8% in the Senate draft.
- Royalty income rules are also under review, potentially expanding the definition of unrelated business taxable income for organizations leveraging brand and logo assets.
- The transportation fringe benefit tax returns—reviving a compliance burden familiar from 2017–2018.
Political Temperature: Divided but Driven
Senator Mike Crapo calls this a bill that prevents “an over-$4 trillion tax hike,” aligning it with efforts to solidify Trump-era tax cuts. Meanwhile, Democratic leadership frames the bill as deepening inequality and threatening essential public funding.
And yet, July 4th remains a target date—still floated by some, but doubted by others—as the legislative window narrows. With procedural hurdles ahead and sharp partisan contrasts, ABGi will continue to monitor what’s happening and keep you informed.
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