We're in August, which means the planning window for 2025 is already shorter than most people realize. Most CPA firms don't start tax planning conversations until October. By then, the more complex, time-sensitive strategies are off the table - there simply isn't enough runway to implement them properly.
This year, that problem is more acute than usual. On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law - one of the more consequential tax bills in recent years. It made several major provisions permanent, introduced new incentives, and created planning windows with real deadlines.
If you haven't started a conversation about what this means for your situation, now is the time.
What the OBBBA Actually Changed
Below are the provisions most relevant to business owners and high-income families. This isn't an exhaustive list - the OBBBA covers hundreds of provisions - but these are the areas where proactive coordination creates real opportunity.
Estate and Gift Tax Exemption: Now Permanent at $15 Million
The OBBBA made the estate and gift tax exemption permanent at $15 million per person ($30 million for a married couple), indexed for inflation. Under prior law, it was set to revert to roughly half that amount at the end of 2025.
This removes the expiration pressure that drove a lot of rushed planning in prior years - but it doesn't eliminate the need for planning. Congress has adjusted these numbers before. Trusts funded today at current values can lock in assets outside your taxable estate regardless of where the exemption goes in the future.
Strategies worth evaluating now: Spousal Lifetime Access Trusts (SLATs), dynasty trusts, and valuation discounts on privately held business interests. Each requires legal work and proper timing - this isn't something you document in December.
QSBS: New Exclusion Tiers and a Higher Cap
Qualified Small Business Stock (QSBS) rules under Section 1202 received a meaningful upgrade for stock acquired after July 4, 2025.
The biggest change: the OBBBA introduced a graduated exclusion schedule - 50% after three years, 75% after four, and 100% after five. Previously, the full exclusion required a five-year hold with no intermediate options. This gives founders and investors more flexibility around liquidity events.
The per-issuer cap also increased from $10 million to $15 million (indexed for inflation from 2027), and the gross asset eligibility threshold rose from $50 million to $75 million - meaning more companies now qualify.
Important note: These changes apply only to stock acquired after July 4, 2025. Pre-OBBBA shares retain the original $10 million cap. If you hold both, the order in which you sell matters.
QSBS eligibility requirements are strict and the documentation standards are exacting. This is an area where early planning - before new shares are issued or acquired - is essential.
Opportunity Zones: Now Permanent, with Rural Enhancements
The Qualified Opportunity Zone (QOZ) program is now permanent under the OBBBA, removing the uncertainty that made long-term OZ planning difficult. Investments in rural-designated zones received additional incentives, including a reduced substantial improvement threshold and enhanced depreciation treatment.
OZs have matured considerably as a planning tool. They're not right for every situation - the capital gain deferral and exclusion benefits require a minimum 10-year hold and specific investment structures - but for business owners with significant realized or anticipated gains, they deserve a serious look.
The key planning consideration here is timing. OZ investments must be made within 180 days of recognizing a qualifying gain. That's a window, not a standing option.
SALT Deduction: Raised to $40, 000, With Important Limits
The state and local tax (SALT) deduction cap was increased from $10, 000 to $40, 000 for tax years 2025 through 2029, with a 1% annual increase through that period. After 2029, it reverts to $10, 000.
This benefit phases out for single filers with income above $250, 000 and joint filers above $500, 000 - reducing back toward the $10, 000 floor. For most high-income business owners, the increased cap will be partially or fully phased out.
For those in high-tax states who do benefit, this affects the deduction bunching and entity structure decisions worth reviewing with your CPA now.
Separately, charitable deductions are affected: itemizing taxpayers must now exceed a 0. 5% AGI floor before deductions kick in, and the rules around Donor-Advised Funds were modified. If you give charitably and itemize, your current structure may need to be revisited.
Business Depreciation: 100% Bonus Depreciation Is Back - Permanently
The OBBBA permanently reinstated 100% bonus depreciation for qualified property placed in service after January 19, 2025. Prior to this, bonus depreciation had been phasing down - it was at 40% in 2025 before the law passed.
The Section 179 deduction limit also increased from $1 million to $2. 5 million, with phaseout beginning at $4 million.
And for business owners in manufacturing, production, or refining - a new 100% depreciation allowance applies to qualified production property, subject to construction and placement-in-service timelines.
The interest deduction rules under Section 163(j) also improved: the limitation calculation reverts to an EBITDA-based formula, which allows more interest expense to be deducted by capital-intensive businesses.
These aren't just provisions for companies buying equipment. With the right coordination - cost segregation studies, strategic capital timing, entity structure - bonus depreciation can meaningfully reduce active income across real estate portfolios, operating companies, and capital projects.
One More Worth Noting: QBI Deduction Now Permanent
The 20% Qualified Business Income (QBI) deduction, which was set to expire at the end of 2025, is now permanent. The rate increases to 23% starting in 2026.
For pass-through business owners, this is significant. It changes the long-term calculus on entity structure decisions - particularly S-corp vs. C-corp tradeoffs - and creates a more stable foundation for multi-year income planning.
The Practical Problem with All of This
The OBBBA creates real opportunity. It also creates real complexity.
Trust structures require attorney coordination and take weeks to implement. QSBS documentation requires entity structure decisions made before shares are issued. OZ investments have 180-day windows. Cost segregation studies require scheduling and professional review. None of this happens in December.
Most CPA firms are doing compliance work right now - they're not resourced to run advanced strategy alongside it. That's not a criticism; it's a structural reality. Business owners who assume their CPA is proactively tracking all of this are often surprised when they ask in October.
The Collective VFO model exists to close that gap. We work alongside your existing CPA and advisory team to evaluate which OBBBA provisions apply to your situation, prioritize by impact and feasibility, and coordinate implementation before deadlines arrive.
If you're a business owner with $500K+ AGI or $2M+ in revenue, and you haven't had a structured conversation about what the OBBBA means for your 2025 picture, that conversation should happen now - not in Q4.
Where Collective VFO Fits
What we coordinate:Tax strategy across your CPA, attorney, and financial team - evaluating OBBBA provisions for your specific situation and coordinating implementation before year-end windows close.
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Collective VFO facilitates strategic coordination across tax, legal, and financial planning disciplines. We do not provide legal, accounting, securities, or investment advisory services directly. Any such services are provided by appropriately licensed professionals. The content in this article is for educational purposes and does not constitute financial, legal, or tax advice. For guidance specific to your situation, consult a licensed professional. Tax law is complex and individual circumstances vary - the provisions discussed here may not apply to your situation without additional analysis.
