EY: New tax law provides a more predictable policy runway for corporate tax planning
The tax and spending bill signed by U.S. President Trump earlier this month makes several corporate-friendly provisions of the 2017 Tax Cuts and Jobs Act permanent, providing a more predictable policy environment for corporate tax planning. Adam Francis, head of EY's Washington Council, noted that this certainty is a key achievement of the bill, but tax law simplification remains insufficient. The bill also involves adjustments to individual income tax, changes to the tax system for multinational enterprises, and the eventual repeal of the once-controversial 'retaliatory tax' provision.

Many companies are still working intensively to calculate how the tax and spending bill signed into law earlier this month by U.S. President Donald Trump will specifically impact their bottom lines. Regardless of the calculation results, Adam Francis, tax policy leader at Ernst & Young and a member of the Big Four accounting firm's Washington council, told CFO Dive that one component of the president's budget proposal provides a more predictable policy runway for corporate tax planning.tax and spending billMany companies are still working intensively to calculate how the tax and spending bill signed into law earlier this month by U.S. President Donald Trump will specifically impact their bottom lines. Regardless of the calculation results, Adam Francis, tax policy leader at Ernst & Young and a member of the Big Four accounting firm's Washington council, told CFO Dive that one component of the president's budget proposal provides a more predictable policy runway for corporate tax planning.
"The bill provides companies with a relatively certain tax environment for the foreseeable future," Francis said. "I think that's a very important outcome of the entire legislative process."
A key factor driving this shift in outlook is that the bill makes permanent several business-friendly provisions of the 2017 Tax Cuts and Jobs Act (TCJA). Francis noted that this includes the so-called "big three" items of the TCJA: those related to capital investment100% corporate bonus depreciation, immediate expensing of research and development costs for U.S.-based companies, and allowing companies to use a more favorable method for calculating interest expense deductions.
Francis said that making these provisions permanent "reinforces" the "foundation" of the TCJA, but at the same time, lawmakers have made no progress on the long-pursued goal of simplifying the tax code. "The permanence of these provisions is, in a sense, a form of simplification... Beyond that, it's hard to see where the tax code has become simpler."
The bill introduces a wide range of tax adjustments, spanning from changes in how individuals are taxed (such as new exemptions for certain tip wages) to complex formula adjustments in the tax system that affect multinational corporations.
Francis cited as an example that, for tax years beginning after December 31, 2025, the 40% deduction for Global Intangible Low-Taxed Income (GILTI) is generally seen as favorable to businesses; meanwhile, some advocates pushing to lower the threshold for the Base Erosion and Anti-Abuse Tax (BEAT) were disappointed that related modifications were not enacted into law.
Additionally, some companies may actually benefit from what the bill does not include. Francis noted that the corporate tax rate, which had caused anxiety among businesses during the presidential campaign, was ultimately left unchanged by lawmakers at 21%.
Furthermore, negotiators from the Trump administration also used the bill to counter the 15% global minimum tax led by the Organisation for Economic Co-operation and Development (OECD) by including a retaliatory tax provision. Francis said the provision was used as a "stick" in negotiations.
Section 899 in one of the draft bills proposed imposing U.S. tax rates of up to 50% on entities and individuals from "discriminatory foreign countries" in response to tax measures deemed "unfair." This is how the provision was worded, according to a June 2 report from Ernst & Young. However, according to CNN on June 27, this so-called "retaliatory tax" was ultimately rejected by the U.S. Treasury and Congress after causing unease among Wall Street and global business leaders. U.S. Treasury Secretary Scott Bessent announced that, after Washington reached an agreement with the Group of Seven (G7) industrialized nations ensuring the global minimum tax would not apply to U.S. companies, he had asked Republicans to abandon this retaliatory tax. Reuters reported on this.
"Interestingly, this was a very hot legislative topic... but we believe it ultimately led to agreements favorable to U.S. multinational corporations," Francis said.