Although the economic landscape facing chief financial officers remains uncertain, the overall tax outlook for U.S. businesses is clearer than it has been in years. Tax experts point out that, thanks to major tax law provisions effective January 1, 2026, tax departments can now confidently develop multi-year tax strategies.

Jennifer Acuña, co-leader of KPMG's Tax Federal Legislative and Regulatory Services practice, said the One Big Beautiful Bill Act (OBBBA), combined with the 2017 Tax Cuts and Jobs Act, has created a stable tax system for large multinational corporations. Acuña, who helped draft the 2017 tax reform legislation on Capitol Hill during President Trump's first term, said, "We don't have a one-size-fits-all recommendation. But what we've been saying is, if you've been sitting on the sidelines, waiting to restructure, considering the U.S. as a potential restructuring jurisdiction, that time is no longer now." She added, "The time has come. If there are opportunities, don't leave them on the table."

Of course, OBBBA also brings some less smooth changes for certain companies and industries. For example, the "no tax on tips" provision has triggered the most significant payroll reporting changes in over a decade, and many hospitality and other tip-oriented businesses are busy adjusting their payroll and W-2 reporting processes. But companies seeking regulatory stability will enjoy a period of stability in the tax arena; Acuña and others say the U.S. political environment means the current tax law is unlikely to change substantially before 2029 (after the next presidential election), or possibly even longer.

21% corporate tax rate

The 2017 Tax Cuts and Jobs Act introduced new concepts, such as an alternative taxation approach for multinational corporations' international profits, but many changes were temporary. OBBBA, passed last year, made many of those changes permanent, providing taxpayers with a stronger sense of stability in tax rules, experts say.

For example, OBBBA set the corporate income tax rate at 21%, which enables companies to better plan long-term tax strategies, said Chris Jones, a partner at Ballard Spahr LLP. Jones, who leads the firm's tax and tax controversy team, said, "In the past, when talking with clients, we often said things like, 'Well, keep in mind, this rate could go up' or 'The rate cut isn't permanent.' Now that part of the conversation is eliminated, and planning around everything else becomes easier."

Other tax experts share the same view. Patrick Brown, co-leader of PwC's National Tax Office, said, "There was considerable uncertainty among businesses about whether the 2017 tax reform would be durable. Many companies weren't sure those changes would last. So they had concerns about the corporate rate, and genuine concerns about new incentives for holding intellectual property in the U.S.—would those measures endure?"

Timing for tax planning

A key element of the new tax law is encouraging companies to base activities and operations in the U.S. The legislation is so significant that companies should consider "fundamental changes to some of their long-standing business structures," said Colleen O'Neill, head of Ernst & Young's national tax department. She said, "We cannot underestimate the potential impact of OBBBA and how it might prompt companies to rethink intellectual property, supply chains, and financing arrangements within their organizations." Brown agreed: "Congress and the Trump administration clearly intend to tilt the scales toward increased U.S. investment. Companies should now consider how to benefit from these changes."

The need for analysis

Experts point out that, due to the complexity of the 2025 act and the interplay among OBBBA's various elements, these changes make tax modeling even more important. O'Neill said, "The R&D provisions are receiving high attention from clients because of all these intersections, as well as the election and its implications for planning." For example, the new rules tax certain qualified intellectual property income at 14%, but related deductions apply at the 21% rate, one tax expert said. Another example: the new rules favor companies' activities in the U.S., such as repatriating non-U.S. intellectual property. But some foreign jurisdictions impose exit taxes on companies transferring intellectual property. Without proper analysis, companies could trigger the U.S. corporate alternative minimum tax introduced by the Inflation Reduction Act of 2022. O'Neill said, "Modeling was very important before OBBBA; it's even more important now." Brown noted that "rough estimates" will no longer be viable.

International tax rates

The 2017 Global Intangible Low-Taxed Income (GILTI) rules fundamentally changed international effective tax rates; the 2025 act renamed and adjusted those rules, and may ease tensions between the U.S. Treasury and the Organisation for Economic Co-operation and Development (OECD) over pushing for a global minimum tax on corporate profits. The new international effective tax rate is approximately 14%, close to the 15% rate promoted by the OECD.

Although the law is already in effect, CFOs still have opportunities to try to influence national tax policy, O'Neill said. The Treasury may issue guidance on how companies should interpret the One Big Beautiful Bill Act, and the Trump administration is "very receptive" to businesses' views on legislative interpretation, she said. The Trump administration "wants to make the U.S. an attractive place to invest and reduce the regulatory burden of tax law interpretation. So we find that for industries or taxpayers facing new issues, the administration is very willing to listen," O'Neill added.