Public Law 119-21 changed several business tax rules at once, and the IRS has published guidance on each in pieces. A year-end planning meeting is the place to bring them together. This checklist lists the provisions this article's sources confirm, what the client should be asked and where the deeper explanation is. It is a meeting guide and not a substitute for the instructions to each form. Each item cites the IRS source it rests on.
1. Bonus depreciation
What changed. Notice 2026-11 explains that the legislation provides a permanent 100 percent additional first-year depreciation deduction for qualified property acquired and placed in service after January 19, 2025. It removed the requirement that property be placed in service before January 1, 2027, and replaced the annual phase-down with the permanent percentage. Taxpayers can elect to deduct 40 percent instead of 100 percent for qualified property placed in service during the first taxable year ending after January 19, 2025. Property is not treated as acquired after the date a written binding contract is entered into.
Ask the client.
- What equipment, vehicles, software and improvements are planned or in service?
- When were the binding contracts signed?
- Is the client better served by accelerating or by electing out for a class?
Go deeper. Section 179 and bonus depreciation and MACRS conventions.
2. Section 179 limits
What the sources give. Section 70306 of the act sets a 2025 maximum of $2,500,000, reduced above $4,000,000 of qualifying property, with a $31,300 SUV cap (Revenue Procedure 2024-40). For tax years beginning in 2026, Revenue Procedure 2025-32 gives $2,560,000, reduced above $4,090,000, with a $32,000 SUV cap.
Ask the client. Total property placed in service, taxable income and whether the business income limit will bind.
3. Domestic research expensing
What changed. The IRS describes section 174A, effective for taxable years beginning after December 31, 2024, as allowing domestic research or experimental expenditures to be deducted when paid or incurred, or capitalized and amortized over at least 60 months. Foreign research costs are amortized over 15 years. Revenue Procedure 2025-28 holds the transition rules, and it sets July 6, 2026 as the deadline for the small business retroactive election on an amended return or administrative adjustment request. That date has passed.
Ask the client.
- Does the business develop software, products or processes?
- Where are the developers and contractors located?
- Was the small business election made for prior years, and was the statement attached?
Go deeper. Section 174A and the research credit.
4. Business interest limitation
What changed. The Instructions for Form 8990 state that for tax years beginning after 2024, adjusted taxable income adds back depreciation, amortization and depletion. Businesses under the small business gross receipts test, which the IRS gives as $31 million for 2025 and $32 million for 2026, are not subject to the limitation.
Ask the client. Total business interest, three-year average gross receipts, related entities and capitalized interest.
Go deeper. Section 163(j) after the 2025 legislation.
5. QBI deduction
What changed. The IRS states that for tax years beginning after 2025, the deduction is the greater of the taxable income limitation amount or the minimum deduction for active qualified business income, and that an active business for this purpose is one in which the taxpayer materially participates under section 469(h). Section 70105 of the act sets the minimum at $400 for a taxpayer with at least $1,000 of qualified business income from active businesses, and raises the phase-in ranges to $75,000 ($150,000 on a joint return). Tip income under section 224 excluded from net profit is not QBI for 2025 through 2028.
Ask the client. Which businesses the owner materially participates in, W-2 wages and qualified property by business, and the expected taxable income.
Go deeper. The QBI deduction after the 2025 legislation.
6. Information return reporting threshold
What changed. Section 70433 of the act raised the section 6041 and 6041A reporting threshold and the related backup withholding threshold from $600 to $2,000 for payments made after December 31, 2025, with inflation indexing for calendar years after 2026. Publication 1099 (2026) describes the change.
Ask the client. Which vendor payments are reportable, whether Forms W-9 are on file and how many information returns the client files in total, since the electronic filing threshold counts them all together.
Go deeper. Form 1099 thresholds for 2026 and W-2 and 1099 filing.
7. Entity and owner pay
The above provisions interact with how the owner is paid and which entity holds the business. Review the S election, reasonable compensation and the estimate calendar. See S corporation vs LLC, S corporation reasonable compensation and estimated tax payments.
How to run the meeting
- Send a one-page pre-read with the questions above, two weeks ahead.
- Bring the year-to-date profit and loss, the fixed asset additions and the payroll and 1099 summary.
- Model the choices. For each decision, show the tax result and the cash result, since a deduction that costs cash the business needs is not a gain.
- Record the decision and the reason in a short memo, signed or confirmed by email.
- Calendar the follow-ups, including elections that need statements on the return and the next estimated payment.
- Check state conformity for each state the client files in. State rules differ.
Book and financial reporting effects
Tax changes feed the income tax provision and deferred taxes for clients with GAAP statements. Enactment affects the provision in the period it occurs. See ASC 740 income taxes for private companies and book-tax differences.
FAQ
Is bonus depreciation mandatory?
Unless the taxpayer elects out for a class of property, the allowance applies.
Has the section 174A small business election closed?
Revenue Procedure 2025-28 sets July 6, 2026 as the deadline for the election on an amended return or administrative adjustment request, so that window has passed.
What is the new information reporting threshold?
$2,000 for payments made after December 31, 2025 that are reportable under sections 6041 and 6041A, per section 70433 of the act and Publication 1099.
CORAA prepares ready-to-review audit files for US CPA firms; see /us.
Sources
- IRS, Notice 2026-11, Interim Guidance on Additional First Year Depreciation Deduction under Section 168(k): https://www.irs.gov/pub/irs-drop/n-26-11.pdf
- IRS, One Big Beautiful Bill provisions: https://www.irs.gov/newsroom/one-big-beautiful-bill-provisions
- IRS, Instructions for Form 8990 (12/2025): https://www.irs.gov/instructions/i8990
- IRS, Qualified business income deduction: https://www.irs.gov/newsroom/qualified-business-income-deduction
- IRS, Publication 1099 (2026), General Instructions for Certain Information Returns: https://www.irs.gov/publications/p1099
- IRS, Revenue Procedure 2025-32, 2026 inflation adjustments: https://www.irs.gov/pub/irs-drop/rp-25-32.pdf
- IRS, Revenue Procedure 2024-40: https://www.irs.gov/pub/irs-drop/rp-24-40.pdf
- Public Law 119-21 (statute text, GovInfo): https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
- IRS, Revenue Procedure 2025-28: https://www.irs.gov/pub/irs-drop/rp-25-28.pdf
- IRS, Questions and answers about the limitation on the deduction for business interest expense, FS-2026-14: https://www.irs.gov/pub/irs-drop/fs-2026-14.pdf
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AU-C references are to AICPA Professional Standards, paraphrased here; read the standard itself before relying on a requirement. This page is guidance, not professional advice. Report an error