Accounting for US tax reform - One Big Beautiful Bill Act and more

Sep 16, 2025

Join Pat Brown, National Tax Office Co-Leader at PwC, and Jennifer Spang, income tax accounting leader with over 25 years of experience, as they delve into the sweeping 2025 US tax reforms. They discuss key changes like permanent bonus depreciation, the return of immediate R&D deductibility, and tweaks to international tax rules such as GILTI and FDII. The conversation also covers the impact on clean energy credits and corporate charitable contributions. Listen in for insights on the future of corporate tax policy and crucial accounting implications!

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INSIGHT

Major TCJA Reversals Made Permanent

Restored bonus depreciation, R&D immediate deductibility (domestic), and interest limitation relief reverse prior sunsets from TCJA.
Congress made these changes permanent and retroactive to 2025, signaling strong policy support for investment and R&D.

ADVICE

Recalculate Deferred Taxes And Model Elections

Reassess deferred taxes, valuation allowances and model impacts from bonus depreciation, R&D elections, and interest deductibility.
Run modeling to evaluate CAMT, BEAT and election choices because deductions and elections affect period costs and ETR.

ADVICE

Weigh The R&D Catch-Up Election Carefully

Consider the R&D catch-up election carefully: accelerate reversal of 2022–2024 capitalized R&D over one or two years.
Model interactions with CAMT and BEAT before electing because large accelerated deductions can trigger other period taxes.

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As sweeping US tax reform takes effect in 2025, corporate taxpayers face important changes. These include extensions of and modifications to key Tax Cuts & Jobs Act (TCJA) provisions as well as expansion of some Inflation Reduction Act (IRA) incentives while accelerating the phase-out of others. In this episode we provide an overview of the key corporate provisions and dive into the related accounting and financial reporting implications. In this episode, we discuss:

03:24 – Extensions and modifications of TCJA domestic tax laws
13:42 – Extensions and modifications of TCJA international tax laws
24:03 – Changes to IRA energy credits
29:30 – Other provisions (e.g., endowments, charitable deductions)
33:19 – Global tax implications and Pillar Two
39:25 – What’s ahead for corporate tax policy and accounting for income taxes

For more information, check out our publications, Accounting for 2025 US tax reform and President Trump signs H.R. 1, the “One Big Beautiful Bill Act”. You can also listen to our related podcast episode, Sustainability now: Facing IRA and clean energy credit uncertainty. Be sure to follow this podcast on your favorite podcast app and subscribe to our weekly newsletter to stay in the loop.

About our guests

Jennifer Spang is PwC’s National Office income tax accounting leader, specializing in tax accounting under US GAAP and IFRS. She has over 25 years of experience helping companies in a variety of industries navigate complex tax accounting matters.

Pat Brown is PwC’s National Tax Office Co-Leader. Prior to joining PwC, he spent 16 years in the private sector, including as the director of tax policy for a Fortune 50 company. Pat has also served in the US Treasury’s Office of Tax Policy as an attorney-advisor and as Associate International Tax Counsel.

About our guest host

Diana Stoltzfus is a partner in the National Office who helps to shape PwC’s perspectives on regulatory matters, responses to rulemakings and policy development, and implementation related to significant new rules and regulations. Prior to rejoining PwC, Diana was the Deputy Chief Accountant in the Office of the Chief Accountant (OCA) at the SEC where she led the activities of the OCA’s Professional Practices Group.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com.

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