While uncertainty bedevils many economic areas CFOs are navigating, the big picture tax outlook for U.S. corporations is more settled than it has been in years.
In 2026 tax departments can confidently develop multi-year tax strategies because of major tax-law provisions that took force Jan. 1, tax specialists said.
The One Big Beautiful Bill Act coupled with the 2017 Tax Cuts and Jobs Act, has created a stable tax regime for large multinational companies, said Jennifer Acuña, co-lead of KPMG Tax's federal legislative and regulatory services practice.
"We don't have one-size-fits-all advice. But what we have been saying is that if you've been on the sidelines, waiting to do some restructuring, looking at the U.S. as a potential jurisdiction for restructuring, we're no longer in a wait-and-see timeframe," Acuña said.
"The time is now. If there are opportunities, don't leave them on the table," said Acuña, who helped draft the 2017 tax law passed during President Donald Trump’s first term when she worked on Capitol Hill.
To be sure, the OBBBA also delivered some changes that are less than smooth for certain companies and industries. For example, the “no tax on tips” provision has ushered in one of the most significant payroll reporting changes in more than a decade and left many firms in the hospitality and other tip-oriented industries scrambling to recast their wage and W-2 reporting processes.
But companies looking for steady regulation will have it for a while in the tax area; the U.S. political environment likely means the current tax code won't materially change until at least 2029, after the next presidential election, or even longer, Acuña and others said.
21% corporate rate
The 2017 Tax Cuts and Jobs Act introduced new concepts, such as an alternative way to tax multinationals' international profits, but many changes were temporary.
Last year’s massive OBBBA made many of those changes permanent, providing taxpayers with a greater sense of tax-rules stability, the specialists said.
For instance, it established a corporate income tax rate at 21%, which enables companies to better plan longer-term tax strategies, Ballard Spahr LLP partner Chris Jones said.
"You would have that conversation with clients and say, 'Well, okay, just remember, this rate could go up,' or 'The rate decrease isn't permanent,' things like that. So it takes off that piece of the conversation and makes planning around everything else" easier, said Jones, who leads his law firm's tax and tax controversy teams.
Others tax specialists agreed. "There was quite a bit of uncertainty on the part of companies about whether or not the 2017 changes were going to have longevity," PwC national tax office co-leader Patrick Brown said.
"A lot of companies weren't necessarily sure they were going to stick. So there were concerns about the corporate rate, there were real concerns about things like this new incentive to own [intellectual property] in the United States," he said. "Would they have staying power?"
Time for tax planning
A key element of the new tax rules is to encourage companies to locate activities and operations in the United States. The legislation is so significant that businesses should consider making "fundamental changes to some of their long-standing business structures," EY national tax department leader Colleen O'Neill said.
"We can't understate the potential implications of OB3 and how it might prompt companies to rethink intellectual property, supply chain, and financing within their organizations," O'Neill said.
Others agreed. "Congress and the Trump administration clearly intended to put a thumb on the scales in favor of increased investment in the U.S.," Brown said. Companies should now consider how to benefit from the changes, he said.
Need for Analysis
The changes put heightened importance on tax modeling because of the 2025 law's complexity and how various elements of OBBBA work together, the specialists said.
"The R&D provision is getting a lot of interest from our clients because of all of these intersections, and about the elections and what it means for planning purposes," O'Neill said.
For instance, the new rules tax certain qualified intellectual property income at 14% but related deductions are applied to income taxed at a 21% rate, a tax specialist said.
Another example: The new rules favor companies' U.S. activities such as onshoring of non U.S. intellectual property. But some foreign jurisdictions impose an exit tax if companies move their IP. Without proper analyses, companies could trigger the U.S. corporate alternative minimum tax, introduced by the Inflation Reduction Act of 2022.
"It was the case pre-OB3 that modeling was very important. It's even more important now," O'Neill said.
“Back of the envelope” estimations won't cut it, Brown said.
International rates
International effective tax rates were fundamentally changed by the 2017 global intangible low-taxed income (GILTI) rules; the 2025 law renamed and reworked those rules and could smooth relations between the Treasury Department and the Organization for Economic Cooperation and Development over a push for a single global minimum tax on corporate profits.
The new international effective tax rate of about 14% is similar to the OECD's push for a 15% rate.
While the law is already in effect, chief financial officers still have a chance to try to influence national tax policy, O'Neill said. The Treasury Department will likely issue guidance on how companies should interpret the One Big Beautiful Bill Act, and the Trump administration "is very interested in hearing from businesses" with 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 on interpretation of tax statutes. And so what we're finding is that industries or taxpayers with novel issues, the government is very open to hearing from them," O'Neill said.
