Past Event

What Transatlantic Businesses Need to Know About the One Big Beautiful (Tax) Bill

Wed. November 12, 2025 08:30 am - 10:30 am !CliftonLarsonAllen (CLA) Offices New York, NY 10165

As the dust settles on President Trump’s sweeping One Big Beautiful Bill Act (OBBBA), transatlantic businesses face a transformed U.S. tax landscape. This timely briefing unpacks the bill’s most consequential provisions for global enterprises navigating U.S. tax exposure, innovation investments, and cross-border planning.

Key discussion topics will include:
• Current State of Play
> Panelists will discuss what’s happening with the shutdown, including potential timing of resolution and the impact of the shutdown on major companies.
> The shutdown has affected the IRS differently than the Department of Treasury, and companies need be aware of the different impacts on both agencies and their ramifications to obtaining certainty from the government during this uncertain time.
> Despite the shutdown, many in the Administration are actively working on guidance projects and open to taxpayer comment and insight.  Panelists will provide recommendations on best practices to engage with the current Administration to seek clarity and conflict resolution.

• The treatment of R&D expenses, both in the United States and internationally
> The OBBBA restored immediate expensing for R&E costs incurred in the United States.  Companies with significant U.S. R&E operations will want to ensure they are properly positioned to take advantage not only of immediate expensing prospectively, but also the catch-up adjustment available for unamortized R&E expenditures remaining from the last few years.
> The OBBBA did not modify the TCJA’s capitalization of foreign R&E costs.  To this extent, companies will want to be aware of opportunities to characterize expenses they may have historically treated as R&E under other Code sections that may offer alternative recovery methods.  Panelists will also discuss current areas where guidance is needed, expected, and ways to shore up tax positions to minimize potential controversy.
> The catch-up adjustment combined with immediate expensing has proven to create adverse tax consequences to companies with significant U.S. R&E operations.  Companies that were not otherwise subject to the corporate alternative minimum tax are being pushed in to the tax due to this significant swing in U.S. R&E deductibility.  Companies’ business interest expense limitation (under Section 163(j)) as well as their BEAT liability and FDII positions are also being impacted.  The panel will discuss these issues and potential avenues to resolve and/or ameliorate the adverse impacts.

• Credits & Incentives: with several credits set to sunset, learn how to maximize benefits under the new regime
> Panelists will discuss the current state of play with tariffs and their impact on corporate tax positions.
> With energy credits sunsetting in the near future, we will discuss planning opportunities around U.S. investment to protect current positions.

• International Tax Shake-Up: changes to GILTI, FDII, BEAT, and Foreign Tax Credits - plus what the exclusion of the proposed “revenge tax” signals for foreign-owned U.S. operations

• Other OBBA Highlights: bonus depreciation, Section 163(j) interest limitations, qualified small business stock inclusion, meals & entertainment, etc.
> Although the OBBBA reinstated 100% bonus depreciation, the lack of guidance may result in companies not being inclined to take advantage of the provision.  Panelists will discuss current existing guidance that companies may rely on to support current investment and bonus depreciation deductions.
> The OBBBA added Section 168(n) to the Code providing 100% depreciation deduction for investments in qualified production property.  We will evaluate the scope of investment that may qualify under the new provision and planning opportunities to protect investment while awaiting guidance.
> The OBBBA may have brought back the “DA” for taxpayers calculating their business interest expense limitations, but the law also enacted an ordering rule that may shutdown certain interest capitalization elections.  Learn what taxpayers may still take advantage of now, when the rules kick in, and the impact other provisions may have on a business’ interest expense limitation.

Join us to decode the bill, demystify the risks, and discover the planning moves that matter most.

 

SPEAKERS:
• Michael Resnick, Counsel, EVERSHEDS SUTHERLAND
• Brian Resnikoff, Director - Tax, CLA (CliftonLarsonAllen)
• Thomas Heck, Partner - USA Business Group & China Business Group, PwC [Moderator]


TIME:
8:30 – 9:00 AM Check-in
9:00 – 10:15 AM Discussion
10:15 – 10:30 AM Networking


REGISTRATION FEE:
> EACCNY Members: Free
> EACCNY non-Members: Free

 

Note: This program is offered as an in-person event and will not be live-streamed or recorded.

 

Registration is closing at 2pm ET on November 11, 2025.