One of the most critical and targeted constituencies of the recent GOP tax cuts is of course manufacturing. With a host of depreciation benefits and write offs geared specifically for equipment, R&D and manufacturers in particular, it’s a clear attempt to accelerate the growth of the sector in the U.S. Some of the key components, especially small and mid-market manufacturers, include:
- Manufacturing Incentives Enhanced: A 100 percent bonus depreciation allowance would apply to certain real estate used in manufacturing. The investment tax credit for advanced manufacturing would increase from 25 percent to 35 percent starting in 2026.
- Expensing Cap More Than Doubled: The Section 179 cap for immediate expensing of business equipment would rise from $1 million to $2.5 million. That means you could deduct the full cost of qualifying purchases in the first year, improving cash flow and simplifying tax planning.
- Full Deduction for R&D Costs Restored: Domestic research and development costs could once again be fully deducted starting in 2025—and small businesses (with under $31 million in annual revenue) could apply this change retroactively to 2022.
- Bonus Depreciation Made Permanent: Businesses could permanently write off 100 percent of the cost of qualifying assets (and certain crops) placed in service after Jan. 19, 2025.
What should manufacturing leaders do now to take advantage? I reached out to EY’s Derek Burgess for some immediate reactions and ideas to make the most of the opportunities.
Burgess is a tax partner at EY with more than two decades of experience working with global manufacturers in cross-border transactions, transformations, business strategy and large international planning projects, including restructurings, supply chain management and OECD BEPS initiatives. Here’s his quick take:
What are clients asking about right now, what are you telling them?
H.R. 1 presents both opportunities and challenges for the manufacturing sector. Clients are delving into the complexities of the nearly 900-page bill, particularly the tax policy changes that comprise a significant portion of the legislation. We’re fielding numerous inquiries about specific tax provisions, effective dates and the phase-in and phase-out timelines.
Supply chain resilience remains a high priority for manufacturers and the international tax changes make evaluation especially critical. Given the intricacies involved, we strongly recommend that companies model a range of scenarios to optimize cash flow and enhance tax efficiency. This approach will help them navigate the new landscape effectively and support the best possible outcomes for their organizations.
What’s the real gold in this, what should top the priority list for manufacturers?
A common theme emerging from our manufacturing clients is that this bill could substantially enhance their capacity to invest and innovate in the U.S. The immediate deduction of costs associated with capital equipment purchases and new factories is a game-changer, potentially boosting investment capacity.
Additionally, the reinstatement of full expensing for domestic R&D is crucial for fueling U.S. innovation. Both provisions are vital for improving first-year cash flow and increasing after-tax returns on investment—key factors that will influence when and where companies decide to invest.
Many companies are looking to automate, need to automate. How best to leverage this to help drive those initiatives?
Automation continues to be a top priority for many manufacturers, and the new legislation can significantly enhance the after-tax economics of these investments. With the ability to immediately expense automation equipment and fully deduct R&D costs related to developing new robotic systems or software, companies can recover a portion of their upfront investments in the same year.
Furthermore, for capital-intensive automation projects financed with debt, the bill restores more favorable interest expense rules by shifting the limitation calculation back to an EBITDA basis, which could lower financing costs. When combined with available state and local incentives, these tax provisions can meaningfully strengthen the financial case for automation initiatives.
How to think about M&A right now, or selling your company? What should executives be considering?
Overall, the passing of the H.R. 1 has created a lot of optimism among manufacturers. While there are certainly trade-offs, the overall outlook is one of momentum and opportunity. Companies looking to execute deals should ensure that they are presenting a clear narrative around how they plan to leverage these tax incentives to drive future growth.
Executives should evaluate their own readiness for acquisition by assessing their financial health and operational capabilities to capitalize on the opportunities presented by the new legislation.
Final thoughts? What’s your big guidance for manufacturing leaders with this?
Consider how to leverage the immediate tax benefits from the H.R. 1 to enhance cash flow and invest in long-term capabilities, while being mindful of the trade environment and shifting U.S. tariff policies. The legislation presents a unique opportunity for manufacturers to rethink their strategies and embrace innovation, investment and growth.
While the complexities of the bill may seem daunting, they also signal a commitment to revitalizing the U.S. manufacturing sector and enhancing its global competitiveness.