Home/All Topics/OBBBA TextSEC. 70311. Modifications related to foreign tax credit limitation. (a) Rules for allocation of certain deductions to foreign source net CFC tested income for purposes of foreign tax credit limitation.—Section 904(b) is amended by adding at the end the following new paragraph: “(5) DEDUCTIONS TREATED AS ALLOCABLE TO FOREIGN SOURCE NET CFC TESTED…

Home/All Topics/OBBBA Text(a) In general.—Section 904(b), as amended by section 70311, is amended by adding at the end the following new paragraph: “(6) SOURCE RULES FOR CERTAIN INVENTORY PRODUCED IN THE UNITED STATES AND SOLD THROUGH FOREIGN BRANCHES.—For purposes of this section, if a United States person maintains an office or other fixed place of…

Home/All Topics/OBBBA Text(a) Increase in deemed paid credit.— (1) IN GENERAL.—Section 960(d)(1) is amended by striking “80 percent” and inserting “90 percent”. (2) GROSS UP FOR DEEMED PAID FOREIGN TAX CREDIT.—Section 78 is amended— (A) by striking “subsections (a), (b), and (d)” and inserting “subsections (a) and (d)”, and (B) by striking “80 percent” and…

Home/All Topics/OBBBA Text(a) Rules for allocation of certain deductions to foreign source net CFC tested income for purposes of foreign tax credit limitation.—Section 904(b) is amended by adding at the end the following new paragraph: “(5) DEDUCTIONS TREATED AS ALLOCABLE TO FOREIGN SOURCE NET CFC TESTED INCOME.—Solely for purposes of the application of subsection (a)…

Home/All Topics/OBBBA TextSEC. 70301. Full expensing for certain business property. (a) Made permanent.— (1) IN GENERAL.—Section 168(k)(2)(A) is amended by adding “and” at the end of clause (i), by striking “, and” at the end of clause (ii) and inserting a period, and by striking clause (iii). (2) PROPERTY WITH LONGER PRODUCTION PERIODS.—Section 168(k)(2)(B) is…

Home/All Topics/OBBBA Text(a) In general.—Section 142(a)(1) is amended to read as follows: “(1) airports and spaceports,”. (b) Treatment of ground leases.—Section 142(b)(1) is amended by adding at the end the following new subparagraph: “(C) SPECIAL RULE FOR SPACEPORT GROUND LEASES.—For purposes of subparagraph (A), spaceport property located on land leased by a governmental unit from…

Home/All Topics/OBBBA Text(a) In general.—Section 48D(a) is amended by striking “25 percent” and inserting “35 percent”. (b) Effective date.—The amendments made by this section shall apply to property placed in service after December 31, 2025. ← Sec. 70307. Special depreciation allowance for qualified production propertyOBBBA TextAll TopicsBack to top ↑Sec. 70309. Spaceports are treated like…

Home/All Topics/OBBBA Text(a) In general.—Section 168 is amended by adding at the end the following new subsection: “(n) Special allowance for qualified production property.— “(1) IN GENERAL.—In the case of any qualified production property of a taxpayer making an election under this subsection— “(A) the depreciation deduction provided by section 167(a) for the taxable year…

Home/All Topics/OBBBA Text(a) In general.—Section 179(b) is amended— (1) in paragraph (1), by striking “$1,000,000” and inserting “$2,500,000”, and (2) in paragraph (2), by striking “$2,500,000” and inserting “$4,000,000”. (b) Conforming amendments.—Section 179(b)(6)(A) is amended— (1) by inserting “(2025 in the case of the dollar amounts in paragraphs (1) and (2))” after “In the case…

Home/All Topics/OBBBA Text(a) Exception to denial of deduction for business meals.—Section 274(o), as added by section 13304 of Public Law 115–97, is amended by striking “No deduction” and inserting “Except in the case of an expense described in subsection (e)(8) or (n)(2)(C), no deduction”. (b) Meals provided on certain fishing boats and at certain fish…

Home/All Topics/OBBBA Text(a) In general.—Section 45S is amended— (1) in subsection (a)— (A) by striking paragraph (1) and inserting the following: “(1) IN GENERAL.—For purposes of section 38, in the case of an eligible employer, the paid family and medical leave credit is an amount equal to either of the following (as elected by such…

Home/All Topics/OBBBA Text(a) In general.—Section 163(j)(8)(A)(v) is amended by striking “in the case of taxable years beginning before January 1, 2022,”. (b) Floor plan financing applicable to certain trailers and campers.—Section 163(j)(9)(C) is amended by adding at the end the following new flush sentence: “Such term shall also include any trailer or camper which is…