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What the 2025 Tax Law Changed for Business Owners

A permanent QBI deduction with a wider phase-in, 100% bonus depreciation, a $2.56 million Section 179 limit, R&D expensing, new W-2 reporting for tips and overtime, and a PTET workaround that survived. Here is what applies in 2026 and what is scheduled for 2027.

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If you own an S corp, partnership, LLC or sole proprietorship, the 2025 tax law (Public Law 119-21, signed July 4, 2025) changed more of your return than any law since 2017. The QBI deduction no longer expires, first-year expensing is back at full strength, research costs are deductible again, and payroll picked up new reporting jobs. This page covers what applies to pass-through owners in 2026 and what is scheduled for 2027.

Quick Answer
For pass-through owners, the 2025 law made the 20% QBI deduction permanent with a wider phase-in ($403,500 to $553,500 joint in 2026) and a $400 minimum, restored permanent 100% bonus depreciation, raised Section 179 to $2,560,000 for 2026, brought back immediate expensing of U.S. research costs and the EBITDA interest limit, and left PTET elections intact. 2027 limits are mostly inflation-indexed; IRS publishes these in late 2026.

The changes at a glance: 2025, 2026 and 2027

Every row is a federal provision of the 2025 law. Figures for 2026 come from IRS Rev. Proc. 2025-32. Where the IRS has not yet published 2027 inflation-adjusted amounts, the table says so; those come out in late 2026.

ProvisionQBI deduction (Section 199A)
What changedThe 20% qualified business income deduction became permanent. The phase-in range above the income threshold widened from $50,000 to $75,000 ($100,000 to $150,000 joint), and a $400 minimum deduction was added for at least $1,000 of QBI from an active business.
Effective datesPermanent; wider phase-in and minimum start with tax years beginning after December 31, 2025
Who it affectsOwners of S corps, partnerships, LLCs and sole proprietorships. Specified service owners (consulting, law, accounting, health, financial services) feel the wider phase-in most.
2026Threshold $201,750 ($403,500 joint). Phase-in ends at $276,750 ($553,500 joint).
2027Thresholds and the $400 and $1,000 minimum amounts are indexed. IRS publishes these in late 2026.
ProvisionBonus depreciation
What changed100% first-year bonus depreciation was restored and made permanent for property acquired after January 19, 2025. Property acquired on or before that date stays on the old phasedown (40% in 2025).
Effective datesProperty acquired and placed in service after January 19, 2025; no end date
Who it affectsAny business buying equipment, vehicles over 6,000 pounds GVWR, software, or other short-life property.
2026100%. Under the old schedule, 2026 would have been 20%.
2027100%. Under the old schedule, 2027 would have been 0%.
ProvisionSection 179 expensing
What changedThe Section 179 limit rose to $2,500,000, with the phaseout starting once qualifying purchases pass $4,000,000.
Effective datesProperty placed in service in tax years beginning after December 31, 2024; indexed after 2025
Who it affectsSmall and midsize businesses that want to expense purchases, including qualifying improvements to nonresidential buildings.
2026$2,560,000 limit; phaseout begins at $4,090,000 of purchases. SUV cap $32,000.
2027Indexed for inflation. IRS publishes these in late 2026.
ProvisionDomestic R&D expensing (Section 174A)
What changedU.S. research and experimental costs can be deducted in the year paid again, instead of amortized over five years. Smaller businesses can apply it retroactively to 2022 through 2024; others can speed up the leftover amortization.
Effective datesTax years beginning after December 31, 2024
Who it affectsSoftware, product and engineering businesses with U.S. research and development costs.
2026Expensing continues. Foreign research stays on 15-year amortization.
2027Same rules; permanent.
ProvisionBusiness interest limit (Section 163(j))
What changedAdjusted taxable income is again computed before depreciation and amortization (an EBITDA-style base), which allows more interest to be deducted by capital-heavy businesses.
Effective datesTax years beginning after December 31, 2024
Who it affectsLeveraged and capital-heavy businesses above the $32,000,000 gross receipts test.
2026EBITDA-style base continues. Small businesses under the $32,000,000 gross receipts test remain exempt.
2027Same rules. The gross receipts test is indexed; IRS publishes it in late 2026.
ProvisionSALT deduction cap
What changedThe itemized cap on state and local taxes rose from $10,000 to $40,000 ($20,000 married filing separately). It shrinks by 30% of modified AGI above $500,000, but never below $10,000. Entity-level PTET elections were left in place.
Effective datesTax years 2025 through 2029; drops back to $10,000 in 2030
Who it affectsOwners in high-tax states. Entity-level PTET elections still work and also lower the MAGI that drives the phasedown.
2026Cap $40,400. Phasedown starts at $505,000 of MAGI, and the cap reaches the $10,000 floor at about $606,333.
2027By statute, 101% of the 2026 amounts: about $40,804 cap and a $510,050 threshold. IRS confirms in late 2026.
ProvisionExcess business loss limit
What changedThe cap on how much net business loss (including active real estate losses) can offset wages and portfolio income each year became permanent. Disallowed amounts carry forward as a net operating loss.
Effective datesPermanent
Who it affectsOwners with a large business loss year, such as a heavy equipment purchase year.
2026$256,000 single, $512,000 joint.
2027Indexed for inflation. IRS publishes these in late 2026.
Provision1099 reporting thresholds
What changedThe Form 1099-NEC and 1099-MISC reporting threshold rose from $600 to $2,000. The Form 1099-K threshold went back to more than $20,000 and more than 200 transactions.
Effective dates1099-NEC and MISC: payments after December 31, 2025. 1099-K: retroactive
Who it affectsEvery business that pays contractors.
2026$2,000 threshold applies to 2026 payments (forms filed in early 2027).
2027The $2,000 base is indexed. IRS publishes the amount in late 2026.
ProvisionNo tax on tips
What changedA new deduction of up to $25,000 of qualified tips, available whether or not you itemize. It phases out by $100 per $1,000 of MAGI over $150,000 ($300,000 joint). Requires a valid SSN and a joint return if married; tips in a specified service business do not qualify.
Effective datesTax years 2025 through 2028
Who it affectsRestaurants, salons and other businesses with tipped employees, which now report tips by occupation for the employee deduction.
2026Same $25,000 limit and phaseout thresholds.
2027Same rules; the limit and thresholds are not indexed. Ends after 2028.
ProvisionNo tax on overtime
What changedA new deduction for the premium portion of overtime the FLSA requires (the "half" in time and a half), up to $12,500 ($25,000 joint). Same $150,000 / $300,000 MAGI phaseout as tips.
Effective datesTax years 2025 through 2028
Who it affectsEmployers of non-exempt hourly staff, who now report qualified overtime separately.
2026Same limits. Employers now report qualified overtime separately on 2026 W-2s.
2027Same rules, not indexed. Ends after 2028.
ProvisionQSBS exclusion (Section 1202)
What changedFor stock issued after July 4, 2025: a 50% exclusion after 3 years, 75% after 4, and 100% after 5. The per-company cap rose from $10,000,000 to $15,000,000, and the gross asset test from $50,000,000 to $75,000,000.
Effective datesStock issued after July 4, 2025
Who it affectsC corporation founders and early investors planning a future sale.
2026Tiered holding periods apply to newly issued stock; older stock keeps the 5-year rule.
2027The $15,000,000 cap and $75,000,000 asset test are indexed after 2026. IRS publishes these in late 2026.
ProvisionEstate and gift tax exemption
What changedInstead of falling to roughly half in 2026, the basic exclusion was set at $15,000,000 per person and made permanent, with inflation indexing after 2026. The GST exemption matches it.
Effective datesDeaths and gifts after December 31, 2025
Who it affectsOwners planning a succession or gifting shares to the next generation.
2026$15,000,000 per person ($30,000,000 per married couple with portability). Annual gift exclusion $19,000 per recipient.
2027Indexed from $15,000,000. IRS publishes these in late 2026.

Worked example (hypothetical, illustrative round numbers)

A consulting S corp owner just above the QBI threshold

A married owner of a consulting S corp files jointly for 2026. Consulting is a specified service business. Their taxable income before the QBI deduction is $500,000, of which $300,000 is qualified business income. The S corp pays $200,000 of W-2 wages, so the wage limit does not bind.

The 2026 joint threshold is $403,500. The 2025 law widened the phase-in range from $100,000 to $150,000.

Income over the threshold
$96,500
Share of the range used, new $150,000 range
64.3%
QBI deduction with the new range: 20% x $300,000 x 35.7%
about $21,400
Share of the range used, old $100,000 range
96.5%
QBI deduction with the old range: 20% x $300,000 x 3.5%
$2,100
Additional deduction from the wider range
about $19,300
Federal tax effect at a 32% marginal rate
about $6,200

Specified service owners lose the deduction entirely once taxable income passes the top of the range, $553,500 joint in 2026. Owners of non-service businesses (construction, manufacturing, most trades, real estate) do not lose it at the top of the range; above it their deduction is limited by W-2 wages and the basis of business property instead.

The deduction itself would have expired after 2025 under prior law. Run your own numbers in our QBI deduction calculator.

Illustrative only. Real results depend on your full return, state rules, and facts this example leaves out. It is not a promise of any tax outcome.

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The QBI Deduction Is Permanent, With a Wider Phase-In

What changed for service and non-service businesses

The 20% deduction for qualified business income from pass-throughs was scheduled to disappear after 2025. The 2025 law made it permanent and kept the 20% rate. Two technical changes start in 2026.

First, the phase-in range above the threshold grows from $50,000 to $75,000 for single filers and from $100,000 to $150,000 for joint filers. In 2026 the deduction begins phasing at $201,750 single and $403,500 joint and finishes at $276,750 and $553,500. That range governs both the wage and property limits for non-service businesses and the full phaseout for specified service businesses.

Second, a minimum deduction of $400 applies to owners with at least $1,000 of QBI from active businesses they materially participate in. It mainly helps small side businesses whose computed deduction would otherwise be tiny. Both the $400 and $1,000 amounts are indexed after 2026.

What did not change: W-2 wages you pay yourself from an S corp are not QBI, and reasonable compensation still matters. A higher salary lowers QBI but raises the wage base for the limit, so the balance is a planning question. Our QBI guide has the full mechanics.

Equipment, Buildings, Research and Interest

Four cost recovery rules that all moved in the same direction

Bonus depreciation is 100% again, permanently, for property acquired after January 19, 2025. Before the law it was on track for 20% in 2026 and zero in 2027. Section 179 also doubled: $2,560,000 of expensing in 2026, phasing out once purchases pass $4,090,000. Bonus has no income limit and can create a loss; Section 179 cannot exceed business taxable income, which is why many owners use both. Heavy vehicles are covered on our vehicles over 6,000 pounds page.

Manufacturers and producers get a new option: 100% first-year depreciation for qualified production property, the portion of a new nonresidential building used for manufacturing, production or refining, if construction begins after January 19, 2025 and before 2029 and it is placed in service before 2031.

Domestic research and experimental costs can be deducted immediately again under new Section 174A, for tax years beginning after 2024, instead of amortized over five years. Businesses that met the small business gross receipts test can apply it back to 2022 through 2024 by amended return, and other businesses can deduct their remaining unamortized balance over one or two years. The research credit itself is covered on our R&D credit page.

The business interest limit again adds back depreciation and amortization when computing adjusted taxable income, for tax years beginning after 2024, which raises the cap for capital-heavy and leveraged businesses.

Payroll, Contractors and Employee Benefits

New reporting duties and bigger tax-free benefits

The tips and overtime deductions are claimed by employees on their own returns, but employers carry the reporting. Starting with 2026 W-2s, qualified overtime and tips (with the worker's occupation) are reported separately so employees can claim the deductions. Payroll systems and job descriptions for tipped and non-exempt hourly staff need to be ready before year-end. Our tips and overtime pages cover the employee side.

For contractors, the Form 1099-NEC and 1099-MISC threshold rises from $600 to $2,000 for payments made after December 31, 2025. The forms you file in early 2026 for 2025 payments still use $600. Payment platforms went back to issuing Form 1099-K only above $20,000 and 200 transactions.

Several employee benefits grew in 2026: the dependent care assistance exclusion rises from $5,000 to $7,500, the employer-provided childcare credit rises to as much as $500,000 ($600,000 for eligible small businesses), and employers can contribute up to $2,500 a year tax-free to an employee's or an employee's child's Trump account.

SALT, PTET and the Excess Business Loss Cap

The owner-level rules around the business

The individual SALT cap rose to $40,400 for 2026, with the 30% phasedown above $505,000 of MAGI. The final law did not restrict pass-through entity tax elections, which earlier drafts would have limited for service businesses. A PTET election still moves state income tax to the entity, outside the individual cap, and because it reduces the income on your K-1 it also lowers your MAGI for the phasedown. See our PTET guide for the state elections.

The excess business loss limit is now permanent. In 2026, net business losses above $256,000 single or $512,000 joint cannot offset wages or investment income that year and carry forward instead. With 100% bonus depreciation back, a big equipment year can run into that cap.

Selling, Raising Capital, and Succession

QSBS and the estate exemption

For C corporation stock issued after July 4, 2025, the QSBS exclusion now phases in: 50% of the gain after three years, 75% after four, and 100% after five. The per-company cap rose from $10,000,000 to $15,000,000, and companies can have up to $75,000,000 of gross assets at issuance. Our QSBS guide covers the rest of the test.

The estate and gift exemption is $15,000,000 per person from 2026 and indexed afterward, rather than falling to roughly half. Succession plans built around a 2026 deadline can be revisited without that pressure.

What Is Scheduled for 2027

Indexing and the few dates that still matter

Bonus depreciation, Section 174A expensing and the EBITDA-based interest limit continue unchanged in 2027. The Section 179 limits, QBI thresholds, the $400 minimum, the excess business loss limit, the $2,000 1099 threshold and the employer childcare credit are all inflation-indexed. IRS publishes these in late 2026.

The employee deductions for tips and overtime run through 2028, so the W-2 reporting continues through then. The individual SALT cap rises 1% a year through 2029 and returns to $10,000 in 2030; PTET has no expiration.

Frequently Asked Questions

Business Owners: common questions

Is the QBI deduction permanent now?

Yes. The 2025 law made the 20% Section 199A deduction permanent. It also widened the phase-in range to $75,000 single and $150,000 joint and added a $400 minimum deduction, both starting with 2026.

What are the 2026 QBI thresholds?

Per IRS Rev. Proc. 2025-32, the 2026 threshold is $201,750 for single and most other filers and $403,500 for joint filers. The phase-in range ends at $276,750 and $553,500. Specified service businesses get no deduction above the end of the range.

Can my business deduct 100% of equipment purchases in 2026?

Bonus depreciation is 100% for qualifying property acquired after January 19, 2025, and Section 179 allows up to $2,560,000 of expensing in 2026. Whether expensing everything in year one is wise depends on your income now versus later, state conformity, and the excess business loss limit.

Did the PTET SALT workaround survive the 2025 law?

Yes. The House version would have limited it for specified service businesses, but the enacted law did not change PTET. State rules, deadlines and credits for owners still vary, so each election is a state-by-state decision.

Do I still need to send 1099s to contractors paid $600?

For 2025 payments, yes; the forms filed in early 2026 still use the $600 threshold. For payments made after December 31, 2025, the Form 1099-NEC and 1099-MISC threshold is $2,000, indexed for inflation after 2026.

What do employers have to report for no tax on tips and overtime?

Starting with 2026 Forms W-2, employers report qualified overtime compensation, and qualified tips with the employee’s occupation, separately so employees can claim the deductions. The IRS provided transition relief for 2025, when this information did not have to appear on the W-2.

Plan 2026 and 2027 Around the New Rules

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