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Which industries will be most impacted by the tax loophole closures in the 2025 bill?
Executive summary
The One Big Beautiful Bill (OBBBA) reshapes incentives and closes several tax loopholes, with the biggest net winners concentrated in manufacturing and information/tech due to restored 100% bonus depreciation, expanded R&D expensing, and new manufacturing facility expensing; Tax Foundation projects $422.6 billion of corporate tax reductions flowing to manufacturing and $136.0 billion to information firms from 2025–2035 [1]. The bill also tightens enforcement on Employee Retention Credit claims and adds a 1% remittance excise tax that directly affect payroll/intermediary services and remittance-heavy sectors [2].
1. Manufacturing: the largest direct beneficiary from closed loopholes and new write‑offs
Journalists and policy shops converge on manufacturing as the industry most impacted — positively — by the package: the OBBBA restores full bonus depreciation, permanently or temporarily expands R&D expensing, and adds a temporary 100% deduction for new manufacturing facilities built 2025–2028 [3] [4]. The Tax Foundation’s modeled industry breakdown shows manufacturing firms receiving about $422.6 billion of the $947.2 billion in reduced corporate tax liability through 2035, making manufacturers the biggest near‑term winners from the bill’s closure of prior phaseouts and its new investment allowances [1].
2. Information and technology: big tax gains tied to R&D expensing
The information sector (software, tech, data services) is another large beneficiary because permanent restoration of immediate domestic R&D expensing and bonus depreciation reduces effective tax on intangible and capital investments; the Tax Foundation quantifies ~$136.0 billion in tax liability reductions to the information sector over 2025–2035 [1]. Professional advisors also note that expanded §174 and R&D rules materially favor firms with high qualified research spending [4].
3. Energy and clean‑tech: losers where credits are phased down or tightened
Several clean‑energy incentives were cut back or scheduled to phase out unless projects meet new tight start/construction windows; wind and solar credits phase out for projects that don’t begin construction by July 4, 2026, and some commercial energy incentives (like portions of 179D and certain vehicle/home credits) are limited under the new law — a direct hit to developers and installers of renewable projects and some EV supply chain segments [5]. Bloomberg Government also flags industry‑tilting rules such as lower royalties for fossil fuels and selective energy credits that shift relative advantage across energy firms, illustrating that the bill benefits some energy subgroups while constraining clean‑energy subsidy flows [6].
4. Dealerships and equipment‑intensive sectors: mixed effects via depreciation and credits
Accounting and advisory firms singled out vehicle dealerships and other capital‑intensive businesses: increased depreciation and asset expensing help dealerships for new asset purchases, while certain commercial vehicle credits for qualified vehicles are limited after 2025 subject to contract timing exceptions — producing winners and losers depending on timing and contract dates [7]. More broadly, industries with heavy equipment needs (dealerships, logistics, distribution) see clear near‑term advantages from bonus depreciation and more generous interest deductibility [7] [3].
5. Financial services, remittance processors, and ERC‑related promoters: enforcement and new taxes
The law tightens enforcement and limits payouts tied to aggressive Employee Retention Credit claims for portions of 2021, and specifically targets promoters of improper ERC claims — a direct enforcement squeeze on tax preparers, payroll firms, and promoters who built businesses around those claims [2]. Separately, a new 1% federal excise tax on certain remittance transfers to foreign recipients affects remittance processors and industries with sizable immigrant remittances [2].
6. Real estate, construction and CAMT interaction: technical winners but sober limits
The OBBBA introduces temporary 100% expensing for qualifying structures and other real‑estate incentives, which can favor construction and domestic real‑asset investment; however, Brookings warns many firms may face the corporate alternative minimum tax (CAMT) interaction that can blunt the net tax benefit by widening the gap between tax and book income [3]. That means construction and real‑estate firms gain tools for expensing, but actual cash‑tax relief may be constrained by CAMT mechanics [3].
7. Nonprofits, charities, and philanthropy: behavioral and budget effects
Advisory pieces warn the bill may discourage some philanthropy by high‑income donors and corporate donors over time, even though some community development incentives were extended; the long‑run effect on giving and nonprofit budgets could be material but is uncertain in timing and magnitude [8].
Limitations and competing perspectives
Practitioners and think tanks agree on the broad industry tilts but disagree on magnitude and long‑run effects. Tax Foundation modeling highlights large corporate tax cuts for manufacturing and information firms [1], while Brookings stresses off‑setting constraints — notably CAMT interactions — that may limit how much cash relief firms actually realize [3]. Available sources do not mention other specific industries outside those covered here; for any firm, the net effect depends on facts such as timing of capital projects, contract dates, and whether Treasury issues mitigating regulations [7] [3].