Overview

• The law reinstates 100% bonus depreciation for property placed in service after Jan. 19, 2025 and raises Section 179 expensing limits to $2.5 million for assets placed in service after 2024.
• It restores an EBITDA-based approach to computing adjusted taxable income under Section 163(j) for tax years beginning in 2025, improving interest expense deductibility for leveraged real estate operations.
• High-rise condos and large multifamily projects with contracts entered after July 4, 2025 are now eligible for the completed contract method under Section 460, deferring revenue recognition until project completion.
• States must reselect Qualified Opportunity Zone tracts starting July 1, 2026 to participate in a permanent zone regime that begins Jan. 1, 2027 under stricter income and contiguity criteria.
• The 20% Qualified Business Income deduction under Section 199A is made permanent and the federal estate tax exemption is fixed at $15 million per individual beginning in 2026, providing long-term planning certainty.