The following is a guest article by Ian Boccaccio, head of Ryan and leader of its income tax practice. The views expressed are solely those of the author.

The One Big Beautiful Bill Act (OBBBA) creates tangible new opportunities for businesses, including 100% bonus depreciation, restoration ofimmediate expensing of domestic research and development costsand permanent credit transferability. For companies that can act quickly and accurately, the potential tax savings and cash flow improvements are substantial. However, the same provisions that create these opportunities also introduce new operational complexities—many corporate tax departments are not yet prepared to handle them.

Teams that cannot fully model the impact of OBBBA will not only face resource strain but may also miss out on tax benefits that require proactive action to capture.

What's at stake

Before OBBBA,domestic research and development costshad to be amortized over five years, bonus depreciation was phasing down, and credit transferability remained an evolving planning tool. OBBBA resets several conditions: bonus depreciation returns to 100% for qualified assets placed in service after January 19, 2025; Section 174A restores full immediate expensing for domestic research and experimental expenditures; and credit transferability becomes permanent, with the purchase of discounted tax credits now an annual routine for most U.S. companies. A company purchasing $100 million in credits can achieve cash savings of $5 million to $9 million.

At the same time, the Act introduces new planning tensions. The additional interest expense deductible under OBBBA may push some multinationals into triggering the Base Erosion and Anti-Abuse Tax (BEAT). Bonus depreciation, while reducing taxable income, may also limit a taxpayer's ability to benefit from the Foreign-Derived Intangible Income (FDII) deduction. These interactions must be modeled before filing.

The state conformity puzzle

Changes to federal tax law do not automatically flow through to state returns, and OBBBA is generating significant state-level volatility in three core areas: GILTI, Section 174A, and depreciation.

Roughly half of the states conform to the Internal Revenue Code (IRC) on a rolling basis, while the others reference older versions or adopt provisions selectively. OBBBA was enacted just as most state legislative sessions were ending, which means most state responses will not become clear until 2026. This pattern is not unfamiliar: after TCJA, state adoption and decoupling dragged on for up to nine years, with California acting only last June—one month before OBBBA was enacted. Tax preparation software and compliance matrices often lag behind these changes, so teams cannot assume their systems will automatically reflect the latest state of the law.

States also show a willingness to interpret federal IRC provisions independently, sometimes in direct contradiction to federal positions. For example, Colorado has, through case law, decoupled from federal LLC classification in its state 80/20 test (used to exclude domestic corporations with substantial foreign elements). New Jersey case law has held that net operating loss (NOL) carryforwards could expire due to the statute of limitations before a legislative override. These independent state interpretations further complicate an already unstable compliance landscape.

On GILTI, about a dozen states currently tax a portion of that income, and the number is growing—Illinois and Minnesota are recent additions, and Massachusetts is actively considering legislation. The new Act renames GILTI to "net CFC tested income," which poses a technical problem for states that reference "GILTI" by name in their statutes. States that allow the related IRC Section 250 deduction will need to update their statutory language to avoid interpretive ambiguity. Illinois has already updated its statutes to address the name change.

On Section 174A, several states have already chosen to decouple from the immediate expensing provision, citing revenue shortfalls. States wishing to preserve maximum capitalization of R&D costs will need to explicitly reference Section 174A in their decoupling provisions while avoiding interference with existing Section 174 treatment. Conflating the two creates compliance risks. The federal unfavorable treatment of foreign R&D costs—using 15-year amortization rather than immediate expensing—also raises constitutional tensions at the state level under Kraft, which prohibits states from discriminating against foreign commerce.

On depreciation, many states cannot allow accelerated deductions as generously as the federal government. Even so, taxpayers may still claim accelerated depreciation under IRC Section 168(n) even in states that have decoupled from existing bonus depreciation rules—because it is a new provision, not an amendment to existing rules. Whether a state's decoupling language covers newly enacted provisions is a question teams should be asking now. Iowa and Oklahoma have administratively included "net CFC tested income" in their state tax bases, adding further complexity for multinationals with filing obligations in those states.

Actions tax teams should take immediately

Staying on top of state law changes and ensuring they flow through to returns is the most important discipline for tax teams right now. This requires manual review of each state's conformity status rather than relying solely on software updates.

On GILTI and net CFC tested income, companies that have not yet challenged state taxing authority should assess the incremental state tax exposure on that income under the OBBBA version and consider filing in affected jurisdictions. The trend of states taxing this income is expanding, and companies that act proactively rather than waiting for audits will be in a stronger position. Similarly, companies should consider taking protective positions on original returns challenging states' application of unfavorable federal treatment to foreign R&D costs under Section 174, given the constitutional constraints of Kraft.

For companies with remaining R&D amortization balances, the accelerated elections available in 2025 and 2026 are time-sensitive. Weighing that election against the amended return path requires case-by-case analysis, considering filing costs, IRS processing delays, and downstream effects on state returns.

Setting clear expectations with senior management is as important as the technical work. Financial leaders should understand that OBBBA's benefits are not automatic and that action windows for several provisions are narrowing.

OBBBA offers real opportunities for companies willing to navigate its complexities. The most time-sensitive provisions center on bonus depreciation elections, the Section 174A acceleration window, and state-level Section 168(n) issues. The companies that capture the most value will be those that treat OBBBA as an ongoing planning discipline, tracking state developments in real time and carefully modeling provision interactions.