The One Big Beautiful Bill Update

The One Big Beautiful Bill Update

Sourced from the Wall Street Journal, July 14, 2025; McDermott Will and Emery July 7, 2005; Seyfarth Shaw LLP Legal Update July 7, 2025; and Pitchbook July 2, 2025.

The final enacted version retained the up-front, accelerated R&D expense and bonus depreciation provisions previously reported in the July Digest. Clean energy tax credits have been severely impacted, but the final version was slightly more favorable to the renewable energy industry. It removed a proposed excise tax on solar and wind projects that sourced imports from China. Tax credits terminate for wind and solar facilities that begin construction after July 4, 2026 if they are not placed in service by December 31, 2027.

While capital gains tax rates remained the same, the law expanded other capital gains tax breaks. Opportunity Zones (there are 19 and 25 designated zones in Ramsay County and Hennepin County, respectively), help investors reduce or eliminate capital gains on any Opportunity Zone investments.

Other clean-tech tax provisions: BESS are subject to pre-OBBBA provisions and generally have until 2033 to begin construction and phase-out provisions. Fuel cell property beginning construction after 2025 is not credit eligible unless it is emissions neutral. Hydrogen facility credits terminate now after December 31, 2027, rather than at the end of 2025 as contained in prior proposals.