VRƵ

Skip to content
Corporate Tax

One year later: What the One Big Beautiful Bill has really meant for tax planning

Nadya Britton  Senior Manager of Enterprise Content for Tax & Accounting, Trade at VRƵ Institute

· 5 minute read

Nadya Britton  Senior Manager of Enterprise Content for Tax & Accounting, Trade at VRƵ Institute

· 5 minute read

A year after its passage, the One Big Beautiful Bill's greatest contribution wasn't disruption — it was clarity, tax professionals say. Here's what that clarity has unlocked, and where new risks are emerging

Key takeaways:

      • Stability is the story — The OBBB’s main value has been predictability for business planning, not sweeping new rules — a sharp contrast to the disruption of prior major tax legislation like the TCJA.

      • Section 1202 is a live opportunity — The expanded QSBS exclusion has reopened planning conversations around corporate structuring that had cooled in recent years.

      • Plan for both today and tomorrow — Practitioners should help clients capitalize on current certainty while preserving flexibility, and they should help clients build tax positions that can hold up to increasingly AI-powered IRS scrutiny.


When major tax legislation lands, the instinct is to brace for upheaval. But one year after the passage of the (OBBB) Act, the consensus among practitioners is notably different: The OBBB didn’t rewrite the rules so much as confirm them, and that distinction has mattered more than it might sound.

Certainty over seismic change

Unlike the (TCJA) — which was passed in 2017, mostly took effect the following year, and forced practitioners to relearn much of the code — the OBBB’s significance lies less in what it changed and more in what it settled. It gave businesses a stable set of rules to plan against, rather than a moving target to which to react.

“From a purely tax lens, it was… easier to unpack than in prior years because there are fewer seismic changes,” says , Partner at Plante Moran, reflecting on the past year under the OBBB. “It was providing a lot of clarity that just [meant], at least for the next several years, we had the rules.”

That clarity is not a small thing. Multi-year business decisions — around such big-ticket items as entity structuring, capital investment, and succession planning — depend on practitioners being able to tell clients that the rules will hold. Thus, OBBB’s real contribution was buying back that predictability.

Section 1202 comes back to life

If one provision captures the OBBB’s practical impact, it’s the revitalization of — the qualified small business stock (QSBS) gain exclusion. The expansion of this program has done more than simply adjust a technical detail; indeed, it has reopened a whole category of planning conversations that had gone quiet.

“The action around the qualified small business stock gain exclusion… has really reinvigorated the Section 1202 planning conversations,” Eckert explains. “Ultimately, what we got was an expansion of the program. So, what that has done is reinvigorated those conversations around planning into corporate structures.”

For founders, investors, and the tax advisors who serve them, that means is back on the table — and often earlier in a company’s lifecycle than before, since the incentive to structure correctly from the outset is now more valuable.

A new kind of advisory opportunity

Of course, stability doesn’t mean passivity. If anything, the OBBB has expanded what tax professionals can offer clients. With a known set of rules, advisors can move beyond compliance and into genuine strategy by helping clients maximize their position under current law while still preparing for the fact that today’s certainty has a shelf life.

That balance — seize the moment, but don’t get comfortable — is a concept that isn’t lost on many tax specialists. “Maximize your opportunities today but also have a long-term view while having flexibility and preserving flexibility wherever you can, and knowing and anticipating that there could be future changes,” Eckert says, framing this moment as a broader opening for the profession, not just a technical one.

Legislative clarity, he argues, gives practitioners a reason to go deeper with clients than simply processing the next filing. “From a practitioner lens, I think [legislative changes] are a huge opportunity… giving us an opportunity to really bring value to our clients and to also get to know our clients better,” he notes. “It’s been, in a certain sense, a great opportunity to just build deeper relationships.”

In other words, the firms getting the most out of this environment aren’t the ones treating the OBBB as a compliance checklist; rather, they’re the ones using it as a reason to have a better conversation with clients about where they’re headed.

The IRS isn’t standing still either

The one area in which practitioners should definitely not get comfortable is enforcement. A smaller IRS workforce doesn’t mean lighter scrutiny — it likely means a different kind. As the agency leans more heavily on AI-driven tools, its ability to examine returns at scale is set to expand even as headcount contracts.

“I think across the board, we’re certainly aware of that and are counseling clients on the need to establish and build positions and think carefully about it,” Eckert explains. “In a world of AI-enabled tools, the scrutiny may actually increase, and the ability for the IRS to quickly and efficiently examine lots of data is something that could certainly exist.”

That means that tax advisors need to help their clients build positions that can withstand more sophisticated review, not less. Meticulous documentation and defensible reasoning matter more, not less, in an environment in which fewer human examiners can still cover more ground with better tools.

One year in, the OBBB’s legacy isn’t a story of dramatic reform, but rather it’s a story of tax firms and their clients finally getting room to plan. The tax advisors making the most of that room are the ones using it to build sharper strategies and deeper client relationships, all while keeping an eye on an IRS that’s quietly getting more capable of deeper examination.


You can find more ofour coverage of the One Big Beautiful Bill Acthere