Tax planning for 2026: The CBIZ guide

December 18, 2025

As tax policy continues to evolve, clarity and forward-looking guidance are essential for businesses and individuals planning for the years ahead. CBIZ (Correspondent) has released its 2026 Tax Planning Guide, offering detailed analysis and practical insights into major U.S. federal tax developments that will shape decision-making well beyond the next filing season.

To download the guide, click here, or read some highlights down below.

A new era of certainty in U.S. tax policy

A central theme of the CBIZ 2026 Tax Planning Guide is certainty. The enactment of the One Big Beautiful Bill Act (OBBBA) has made several previously temporary provisions permanent, fundamentally changing long-term tax planning assumptions for both businesses and individuals. According to CBIZ, this permanence allows organisations to move from short-term, reactive planning to more strategic, multi-year tax decision-making.

The guide spans business taxation, individual tax planning, international tax rules, and estate and gift considerations, making it particularly relevant for professional services firms, multinational businesses, investors, and high-net-worth individuals.

Key business tax provisions to watch

Immediate deductibility of Research & Experimental (R&E) expenses

One of the most impactful changes for businesses is the permanent restoration of immediate deductibility for domestic R&E expenses. Under new IRC Section 174A, companies may deduct qualifying domestic R&E expenditures in the year incurred rather than amortising them over five years.

This provision supports innovation-driven sectors such as technology, life sciences, manufacturing, and professional services. Importantly, foreign R&E costs remain subject to 15-year amortisation, reinforcing incentives for U.S.-based research activity.

100% bonus depreciation made permanent

The OBBBA reinstates and permanently extends 100% bonus depreciation for qualifying property placed in service after 19 January 2025. This allows businesses to fully expense eligible capital investments in the year of acquisition, significantly improving cash flow and return-on-investment calculations.

CBIZ notes that cost segregation studies become even more valuable under this framework, particularly for real estate and capital-intensive industries. However, state-level conformity varies, making multistate planning essential.

Qualified Production Property (QPP): Incentivising manufacturing

A notable new provision is the introduction of Qualified Production Property (QPP), which allows a 100% depreciation deduction for certain nonresidential real property used directly in manufacturing, production, or refining activities. This incentive applies to qualifying projects that begin construction after 19 January 2025 and before 2029.

For manufacturers and industrial investors, QPP represents a significant departure from traditional 39-year depreciation timelines, although eligibility requirements are strict and professional advice is strongly recommended.

Relaxation of the business interest limitation

The guide highlights the relaxation of the IRC Section 163(j) business interest limitation, particularly beneficial for capital-intensive and highly leveraged businesses. By recalculating limitations using EBITDA rather than EBIT, the new rules allow greater interest deductibility without offsetting the benefits of accelerated depreciation.

Expanded incentives for investment and growth

Qualified Small Business Stock (QSBS) enhancements

The OBBBA expands the benefits under Section 1202 Qualified Small Business Stock, introducing tiered capital gains exclusions and increasing thresholds for eligible companies. These changes enhance the attractiveness of U.S. startup and growth-stage investments, particularly for founders and private equity investors.

However, the guide emphasises that QSBS eligibility remains complex and that state-level tax treatment may differ from federal rules.

Qualified Opportunity Zones 2.0

The guide outlines a permanent extension of Qualified Opportunity Zones, with rolling 10-year designations beginning in 2027. Revised rules place greater emphasis on rural investment and streamline reporting requirements, offering renewed planning opportunities for real estate and alternative investment clients. Timing remains critical, as the tax treatment differs depending on when gains are invested.

Clean energy incentives

While the Inflation Reduction Act previously expanded clean energy incentives, the CBIZ guide explains that the OBBBA scales back or accelerates the expiration of several credits. Residential solar credits, electric vehicle credits, and certain commercial energy deductions now have earlier sunset dates.

Some incentives remain, such as those related to nuclear, geothermal, and battery storage, but the overall policy direction signals contraction. CBIZ advises taxpayers to act promptly to secure available benefits before they expire.

International tax changes affecting multinational groups

For internationally active businesses, the guide details important changes to GILTI, FDII, BEAT, and Controlled Foreign Corporation (CFC) rules, effective for tax years beginning after 31 December 2025. These reforms generally increase effective tax rates and tighten expense allocation rules, increasing compliance complexity.

Multinational groups are encouraged to reassess global structures, foreign tax credit utilisation, and cross-border financing strategies in light of these changes.

Individual and private client considerations

The CBIZ guide also addresses significant updates for individuals, including permanent TCJA-era tax brackets, increased standard deductions, and new temporary deductions for tip income, overtime pay, seniors, and certain auto loan interest. Estate and gift tax exemptions are made permanent at inflation-adjusted levels, providing long-term clarity for wealth and succession planning.

What this means

The CBIZ 2026 Tax Planning Guide underscores the importance of early, proactive planning. The permanence of many provisions enables more reliable forecasting, but the complexity of eligibility rules, state conformity, and international implications reinforces the need for coordinated, cross-border tax advice.

By staying informed of these developments and collaborating with trusted partners in the U.S. market, Kreston Global firms can help clients navigate change with confidence and identify opportunities embedded within the new tax landscape.

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