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The Impact of the One Big Beautiful Bill Act on Family Offices

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Written by: Steven Saltzstein | Founding CEO of the FORCE Family Office

I. Introduction

The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, represents a landmark legislative package with profound implications for family offices and high-net-worth individuals (HNWIs). Far from being merely a collection of tax code adjustments, the OBBBA is a strategic realignment of federal policy designed to incentivize domestic investment, drive innovation, and reshape wealth transfer mechanisms.

This comprehensive bill necessitates a proactive re-evaluation of existing financial strategies by family offices and HNWIs. Below is a concise breakdown of its key provisions and the immediate actions to consider:

  • Permanent Opportunity Zone (OZ) Program:
  • The OBBBA formalizes the permanence and expands the Opportunity Zone program, establishing recurring 10-year designations and enhancing basis step-ups for qualifying investments.
    • Family offices and HNWIs should revisit capital gains from recent liquidity events (business sales, real estate exits) and explore rolling them into Qualified Opportunity Funds (QOFs) for long-term tax deferral, potential exclusion, and impact-driven investing in underserved communities.
  • Enhanced Qualified Small Business Stock (QSBS) Benefits:
  • The bill significantly boosts QSBS benefits by raising the gross asset cap to $75 million, increasing the tax-free gain limit to $15 million, and introducing a graduated exemption structure (50% after 3 years, 75% after 4, 100% after 5).
    • Family offices and HNWIs should evaluate existing and prospective venture capital and private equity investments for QSBS eligibility. Structure new investments to maximize these enhanced tax exclusions, particularly in high-growth small businesses.
  • Increased Estate and Gift Tax Exemptions: Countering previous expectations, the OBBBA permanently raises federal gift, estate, and Generation-Skipping Transfer (GST) tax exemptions to $15 million per individual (indexed for inflation).
    • Family offices and HNWIs should review and potentially accelerate wealth transfer planning. Reassess existing trusts, family foundations, and succession plans to leverage these higher exemption amounts, optimizing intergenerational wealth transfer strategies.
  • Restoration of 100% Bonus Depreciation:
  • The bill reinstates full 100% bonus depreciation for qualifying business assets placed in service after December 31, 2024, including those used in operating businesses and, notably, private aircraft used for business purposes.
    • For family offices investing in or owning operating businesses (e.g., manufacturing, technology), leverage this for immediate deductions to improve cash flow and IRR. Consider strategic acquisitions of business-use aircraft, ensuring strict adherence to documentation and business-use requirements to capitalize on significant first-year write-offs.
  • Restored 100% R&D Expensing:
  • Domestic Research & Development expenditures can now be immediately and fully deducted, a significant reversal from prior amortization requirements.
    • For direct investments or portfolio companies engaged in R&D, this provides immediate tax savings. Encourage portfolio companies to capitalize on this for accelerated innovation and increased profitability.
  • Expanded Section 179 Expensing:
  • The bill enables 100% expensing of "qualified production property" under Section 179.
    • If your family office owns production facilities or invests in manufacturing ventures, utilize this for upfront tax relief on new equipment and machinery. Ensure careful structuring to avoid limits and recapture rules.
  • Permanent Corporate & Pass-Through Tax Cuts:
  • The OBBBA retains the 21% corporate tax rate and permanently raises the 20% pass-through deduction to 23%.
    • For family offices operating active businesses through pass-through entities (LLCs, S-corps, partnerships), this delivers a permanent boost to after-tax returns. Evaluate existing entity structures to ensure maximum tax efficiency.
  • Increased State and Local Tax (SALT) Deduction Cap:
  • The cap on SALT deductions is increased from $10,000 to $40,000 for individuals until approximately 2029.
    • While still capped, this offers some relief for those in high-tax states with significant real estate holdings or state income tax liabilities. Factor this into personal tax planning, though high-income earners may still face phase-outs.
  • Strategic Shift: End of IRA Clean-Energy Credits:
  • Many renewable energy tax benefits introduced under prior legislation are phased out or sharply curtailed.
    • Family offices and HNWIs should reallocate capital away from legacy IRA-era clean energy targets. Seek new investment opportunities aligned with the OBBBA's incentivized sectors, such as domestic manufacturing and semiconductor production.
  • Incentives for Domestic Semiconductor/Manufacturing & AI/Supply Chain Mandates: The OBBBA provides substantial tax credits for domestic chip production and federal investment in U.S.-based AI infrastructure, coupled with strict domestic content and sourcing requirements.
    • Family offices and HNWIs should explore investment opportunities in U.S.-based semiconductor fabrication, advanced manufacturing, and AI infrastructure. Be prepared for rigorous supply chain due diligence, favoring compliant startups and established companies that align with domestic sourcing mandates.

The OBBBA marks a new era for capital allocators. Proactive engagement with seasoned tax, legal, and financial advisors is critical to navigating these changes, maximizing benefits, and strategically positioning your wealth for long-term growth and impact.

II. The OBBBA – A New Era for Wealth and Investment

The enactment of the One Big Beautiful Bill Act (OBBBA) on July 4, 2025, marks a pivotal moment in U.S. legislative history. This comprehensive framework, informally referred to earlier as the "Big Beautiful Bill" during its legislative journey 15, consolidates diverse policy priorities into a single, sweeping legislative package.2 Its extraordinary breadth and ambition position it as one of the most consequential pieces of legislation in recent congressional history, poised to reshape federal policy across nearly every major sector of the American economy.2 While initial discussions highlighted its potential inclusion of Opportunity Zone legislation 15, its ultimate passage, confirms its status as an enacted law with widespread implications.

For long-term capital allocators, including family offices and HNWIs, the OBBBA transcends mere policy adjustments; it serves as a powerful signal, one that shows the government's commitment to tax structures that reward productive capital deployment. This signal compels a reevaluation of current tax postures, a fresh consideration of impact-driven strategies, and a critical assessment of whether existing estate frameworks possess the necessary resilience in the face of evolving legislation.5 The provisions within the OBBBA will directly influence investment returns, strategies for wealth preservation, and the efficacy of philanthropic endeavors, thereby necessitating a comprehensive strategic review of current plans and a diligent identification of emerging opportunities.5

This white paper is designed as a strategic roadmap for family offices and HNWIs. Its purpose is to translate the OBBBA's intricate provisions into clear, actionable insights, empowering sophisticated investors with the knowledge required to effectively position their organizations and wealth in response to this transformative legislation.2 By dissecting the core components of the OBBBA, this analysis aims to equip readers with the foresight and understanding necessary to capitalize on the new landscape of incentives and regulations.

III. Strategic Deep Dive: Key OBBBA Provisions and Their Impact

A. Opportunity Zones (OZs): Permanent Incentives for Impact Investing

The OBBBA fundamentally reshapes the landscape of Opportunity Zone (OZ) investments, formally making the program permanent.6 This pivotal shift transforms OZs from a temporary incentive into a core component of strategic planning for long-term capital allocators.15 The permanence ensures that the compelling benefits of capital gains deferral and exclusion remain available, offering wealthy families a robust mechanism to reposition appreciated assets—whether from business sales, portfolio exits, or real estate windfalls—into investments that serve both financial return objectives and broader social impact goals.15

Beyond permanence, the program is expanded with recurring 10-year designations beginning in July 2026.6 This provides a stable, predictable framework for future investment cycles. Furthermore, the OBBBA introduces enhanced basis step-ups for investments held for at least five years: a standard 10% step-up and a more substantial 30% step-up specifically for investments channeled into rural opportunity funds.6 To facilitate greater investment in these underserved areas, rural zone improvement requirements have also been eased.6

The formal permanence of OZs fundamentally alters their perception and utility for investors. Previously, OZs were often viewed as a temporary tax arbitrage opportunity, primarily for deferring capital gains, with the "temporary incentive" aspect creating uncertainty about their long-term viability.15 By establishing formal permanence, the OBBBA transforms OZs into a stable, enduring framework for capital deployment. This allows family offices to confidently integrate OZs more deeply into their core strategic asset allocation models, moving beyond opportunistic, short-term plays. This stability encourages the development of more sophisticated, multi-year investment pipelines within Qualified Opportunity Funds (QOFs), fostering deeper engagement with community development and impact investing objectives.

The enhanced basis step-ups for rural opportunity funds and the eased rural zone improvement requirements are poised to redirect capital to previously overlooked geographic areas.6 Historically, many OZ investments concentrated on urban or suburban areas with existing development potential. The additional 20% basis step-up (from 10% standard to 30% for rural funds) creates a significant financial inducement to direct capital towards rural communities. This, combined with eased regulatory hurdles, reduces the perceived risk and increases the potential return for rural projects. This shift could lead to a broader geographic diversification of impact investments for family offices, unlocking new opportunities in sectors like sustainable agriculture, renewable energy in rural areas, or critical rural infrastructure development, thereby aligning financial returns with broader societal benefits.

A critical implication for existing OZ investors is the requirement that deferred gains from the original OZ program must be recognized by the end of 2026.6 This necessitates immediate and proactive tax planning. Investors who deferred capital gains into OZs under the original program now face a hard deadline for recognition. This is not a passive event; it demands active tax management. Family offices must immediately assess their QOF holdings, calculate potential gain recognition, and explore available mitigation strategies. The explicit mention of tools such as loss harvesting, charitable remainder trusts, or bonus depreciation strategies 6 highlights specific, sophisticated mechanisms that will be critical for managing this upcoming tax event. This creates a direct demand for specialized tax advisory services and potentially new investment vehicles designed to manage this specific tax obligation.

B. Estate and Gift Tax Thresholds: Bolstering Intergenerational Wealth Transfer

The OBBBA introduces significant and permanent changes to federal estate, gift, and generation-skipping transfer (GST) tax exemptions. Effective January 1, 2026, the federal exemption for these taxes is permanently raised to $15 million per U.S. citizen and U.S. domiciled non-citizen individual.5 These exemptions will be subject to annual adjustments for inflation thereafter.5 This represents a notable increase from the $13.99 million per person exemption in 2025 under the Tax Cuts and Jobs Act (TCJA) and, crucially, reverses the scheduled "sunset" in 2026, which would have seen the exemption significantly reduced to an estimated $7 million per person.5 The maximum tax rates for gift, estate, and GST taxes remain unchanged at 40% 5, and the $60,000 exemption for estates of non-citizen, non-resident individuals owning U.S. situs assets also remains the same.5

This permanent increase to $15 million directly contradicts earlier speculation and eliminates the uncertainty surrounding the TCJA's scheduled sunset.15 Many HNWIs and their advisors were preparing for a significant reduction in estate tax exemptions in 2026, which would have necessitated urgent, potentially complex, and aggressive gifting strategies. The OBBBA's action to not only maintain but increase the exemption and make it permanent provides immense relief and planning certainty. This allows for a more deliberate and less rushed approach to estate planning, shifting from a reactive stance to a proactive, long-term strategic one. It also validates past planning that assumed higher exemptions would persist.

The higher exemptions allow for a fundamental re-evaluation of estate planning priorities. When estate tax exemptions are low or uncertain, tax minimization often dominates estate planning discussions. With the OBBBA's higher, permanent exemptions, many families will find their estates fall below the taxable threshold, or at least have significantly reduced tax exposure.5 This allows advisors and families to focus on equally critical, non-tax aspects of wealth management: robust asset protection (e.g., against creditors or divorce), efficient asset management for beneficiaries, and seamless business succession planning.5 This represents a maturation of wealth planning, moving beyond mere tax avoidance to comprehensive wealth governance and legacy building.

Even with higher exemptions, sophisticated strategies like grantor retained annuity trusts (GRATs), charitable lead annuity trusts (CLATs), and dynasty trusts remain highly valuable.6 The larger exemption amounts mean that these tools can be used to transfer even greater amounts of wealth out of the taxable estate, potentially leveraging appreciation over time. For ultra-high-net-worth families whose estates may still exceed the $15 million per individual or $30 million per married couple thresholds, these tools become even more potent. For those below the threshold, they can still be utilized for asset protection, control, and long-term philanthropic objectives, demonstrating their enduring relevance in a comprehensive wealth management strategy.

C. Depreciation and Expensing Incentives: Fueling Business Investment

The OBBBA delivers a significant boost to innovation and capital investment through several key depreciation and expense provisions.

1. Restoration of 100% Bonus Depreciation

The OBBBA permanently reinstates 100% bonus depreciation for qualified property placed in service after January 19, 2025.6 This provision allows businesses to immediately deduct the full cost of eligible equipment, machinery, and certain building improvements in the year they are incurred.8

  • Family Office Angle: This is ideal if your family office is investing in or owns operating businesses or manufacturing entities. The ability to front-load deductions immediately upon asset acquisition significantly improves cash flow and enhances the internal rate of return (IRR) on capital expenditures. This applies to active business assets, not passive holdings; you need to actually operate the business or have a material participation.

2. Enhanced Qualified Production Property (QPP) Deductions

A new provision creates a 100% deduction for the adjusted basis of Qualified Production Property (QPP).8 QPP includes non-residential real property used as an integral part of qualified production activity, defined as manufacturing, production, or refining of tangible personal property.8 To qualify, construction for QPP must begin after January 19, 2025, and before January 1, 2029, with the property placed in service before January 1, 2031.8

  • Family Office Angle: If your family office owns production facilities or is involved in manufacturing investments, this adds another layer of upfront tax relief. It broadens the scope of eligible investments beyond just the operating companies themselves to the physical infrastructure that supports them. A cost segregation study will be needed to break out costs and determine the portion of the real estate qualifying as production property.8

3. Immediate Research & Development (R&D) Expensing

Domestic Research and Development (R&D) expenditures will become immediately deductible for tax years beginning after December 31, 2024.6 This crucial change enables businesses to deduct these costs in the year they are incurred, a departure from the previous requirement to capitalize and amortize them over several years.6 For small businesses, specifically those with under $31 million in gross receipts, the OBBBA offers a significant retroactive benefit: they may elect immediate expensing for R&D expenditures incurred from 2022 to 2024.6 This retroactive provision has the potential to unlock substantial tax savings for these businesses, allowing them to amend prior-year filings and request refunds for previously paid taxes on capitalized expenditures.6 Any unamortized R&D expenditures from prior years can be deducted in 2025 or split between 2025 and 2026.8

  • Family Office Angle:
  • The immediate expensing of R&D is a powerful economic incentive designed to stimulate innovation. It significantly reduces the after-tax cost of R&D 6, directly incentivizing companies to invest more heavily and more quickly in new technologies, equipment, and processes domestically. For family offices investing in early-stage or small-cap companies, the retroactive expensing provides an unexpected infusion of capital, improving financial health and accelerating growth potential for portfolio companies. Investors must now incorporate these R&D provisions into their due diligence, as understanding how a company leverages these tax benefits can reveal a more accurate picture of its true profitability and cash-generating capacity.

D. Qualified Small Business Stock (QSBS) Benefits: Enhanced Growth Equity Opportunities

The OBBBA significantly enhances and broadens the Qualified Small Business Stock (QSBS) exclusion, creating new and expanded planning opportunities for high-net-worth individuals and families.5

Key changes include:

  • Increased Aggregate Gross Assets Ceiling:
  • The maximum aggregate gross assets an issuing company can have at the time of QSBS issuance has been raised from $50 million to $75 million.5 This expands the universe of eligible small businesses whose stock can qualify for the QSBS exclusion.5
  • Increased Maximum Gain Excludable:
  • The maximum gain excludable from gross income by QSBS holders has been increased from $10 million to $15 million.5 This significantly increases the potential tax savings for investors, allowing them to exclude a larger portion of their capital gains from QSBS.5
  • Tiered Exclusion for Shorter Holding Periods:
  • The OBBBA introduces a tiered exclusion system based on the holding period 5. For shares held for a minimum of only three years, 50% of QSBS gain is excludable from gross income.5 The exclusion increases to 75% for shares held for a minimum of four years.5The full 100% exclusion remains for shares held for five years or more.5

The tiered exclusion for shorter holding periods significantly reduces the liquidity risk associated with early-stage investments. The OBBBA's tiered system allows investors to realize partial tax-free gains sooner 5, providing a "softer landing" or earlier partial exit option. This makes venture capital and growth equity investments more palatable for family offices seeking a balance between high growth potential and reasonable liquidity, broadening the appeal of private market investments.

The increased asset ceiling to $75 million addresses a critical gap in the private investment landscape.5 By raising the QSBS limit, the OBBBA makes these "missing middle" companies highly attractive for family offices and HNWIs, incentivizing investment in a crucial growth stage.

Given the significant tax advantages, family offices must now proactively identify and structure investments to qualify for QSBS. This includes rigorous due diligence on target companies' asset bases at issuance and ensuring compliance with all QSBS requirements. Furthermore, the ability to leverage QSBS through strategic gifting and trust planning 6 means that wealth advisors should integrate QSBS considerations into overall estate planning, potentially using these shares for philanthropic endeavors or intergenerational transfers to maximize tax efficiency.

E. Corporate & Pass-Through Tax Cuts: Permanent Efficiency Boost

The OBBBA provides a permanent tax efficiency boost for operating entities by retaining the Tax Cuts and Jobs Act (TCJA) corporate tax rate and enhancing the pass-through deduction.5

  • Corporate Tax Rate:
  • The U.S. corporate income tax rate remains permanently fixed at 21%.5 This relatively low rate compared to other developed countries creates a strong incentive for international families to continue structuring investments and other holdings using U.S. companies.5
  • Enhanced Pass-Through Deduction (Section 199A):
  • The OBBBA makes permanent the existing 20% qualified pass-through deduction, with several beneficial enhancements.6 The income thresholds for phase-ins now begin at $75,000 for single filers and $150,000 for joint filers, with a new $400 deduction floor for actively participating owners.6
  • Family Office Angle:
  • Owning operating entities (e.g., through LLCs, S-corps, partnerships) yields a permanent tax efficiency boost. These provisions offer substantial after-tax opportunities for qualifying flow-through businesses. It's critical to note that these benefits primarily apply to readers who own or manage active businesses; passive portfolios do not benefit directly.

F. Increased SALT Deduction Cap: Relief for High-Tax States

The OBBBA temporarily increases the State and Local Tax (SALT) deduction cap for individuals.6 The cap goes from $10,000 to

$40,000 for married joint filers through 2029 before reverting to $10,000 thereafter.6 Importantly, the widely used Pass-Through Entity Tax (PTET) workaround remains fully preserved, benefiting many family offices, especially in high-tax states.6

  • Family Office Angle:
  • This provision is particularly helpful if your family office or its members are in high-tax states and own real estate or pay significant state taxes. Family offices should strategically evaluate state tax payments and PTET elections to maximize these temporary benefits. However, it's a critical view that the deduction is still capped and phases out for incomes over $500,000 (Modified Adjusted Gross Income).

G. Semiconductor & Advanced Manufacturing Tax Credits: Driving Domestic Industrial Growth

The OBBBA provides a major impetus to domestic manufacturing, particularly bolstering the U.S. semiconductor industry.7 This legislative package introduces significant tax incentives designed to encourage onshoring and expansion of critical production capabilities.

Key provisions include:

  • Semiconductor Investment Tax Credit:
  • The existing 25% investment tax credit for domestic chip production has been substantially expanded to 35% for qualified semiconductor fab projects that commence construction before the end of 2026.7 This is also known as the Advanced Manufacturing Investment Credit.8 This 10-point increase sends a powerful message to chipmakers and investors that the U.S. is serious about anchoring critical manufacturing capacity on its soil.7
  • Permanent 100% Bonus Depreciation:
  • As discussed earlier, the OBBBA permanently reinstates 100% bonus depreciation for qualifying property acquired and placed in service after January 19, 2025.8 This allows manufacturers to expense the entire cost of equipment and certain building improvements immediately, providing a substantial immediate incentive for reinvestment.8

The substantial tax credits and depreciation benefits for semiconductor and advanced manufacturing signal a clear, aggressive U.S. industrial policy aimed at bolstering domestic production and supply chain independence. These provisions go beyond mere tax relief; they represent a direct government signal and financial commitment to re-shore critical manufacturing capabilities. The 35% investment tax credit is a powerful subsidy designed to make U.S. manufacturing competitive globally.7 For family offices, this means that investments in these sectors are not just market-driven but also strategically aligned with federal priorities, potentially benefiting from a more stable regulatory environment and future government support. It is a clear invitation to participate in a national economic transformation.

The specific deadlines for construction and placement in service create a time-sensitive window for maximizing these benefits. The warning that "chip companies that move fast will be rewarded, but hesitation could end up being costly as the incentives are time limited" 7 highlights the critical nature of these deadlines. Family offices cannot afford to delay due diligence or investment decisions if they wish to capture the full 35% semiconductor credit or the QPP deduction. This urgency implies a need for streamlined investment processes and rapid decision-making, potentially favoring family offices that are agile and have established investment pipelines in the industrial sector.

H. Foreign-Derived Intangible Income (FDII) Changes: Realigning International Tax Strategies

The OBBBA introduces a comprehensive overhaul of the concepts previously known as Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI).9 Under the new legislation, FDII is renamed Foreign-Derived Deduction Eligible Income (FDDEI), and GILTI is renamed Net CFC

Tested Income (NCTI).9

The OBBBA permanently reduces the Section 250 deduction rates for these categories: FDDEI drops to 33.34% (from 37.5%), and NCTI drops to 40% (from 50%).9 After factoring in the full application of 90% foreign tax credit allowance provisions, this generally results in an effective tax rate of 14% for both FDDEI and NCTI.9

Crucially, the OBBBA eliminates the deemed tangible income return (DTIR) and net deemed tangible income return (NDTIR), which were previously integral to calculating FDII and GILTI.9 This fundamental change shifts the calculation from an asset-based approach, which allowed a 10% return on qualified business asset investments (QBAI) to reduce the taxable base, to an income-based approach that taxes the full net income without this tangible asset offset.9 These changes are effective for taxable years beginning after December 31, 2025.10

The elimination of the tangible income return (DTIR/NDTIR) represents a fundamental shift in how the U.S. taxes foreign-derived income, moving away from incentivizing tangible asset investment abroad. By removing this, the OBBBA signals a move towards taxing a broader portion of foreign income, particularly intangible income, without that offset.9 This could be interpreted as an effort to discourage "offshore profit shifting" and potentially encourage more domestic intangible asset development or repatriation of intellectual property. For family offices, this means that the tax benefits of structuring operations with significant tangible assets abroad are diminished, requiring a re-thinking of global supply chains and intellectual property ownership.

Despite the reduced deduction rates, the altered calculation methodology adds layers of complexity for family offices with multinational business interests. The renaming of FDII/GILTI and the removal of DTIR/NDTIR necessitates a complete re-modeling of international tax projections.9 The interaction with foreign tax credit limitations also becomes more intricate, as the OBBBA significantly narrows the allocation and apportionment of deductions for FTC limitation purposes, with most deductions now allocated to U.S.-source income rather than GILTI (NCTI).9 This increased complexity means family offices will require more sophisticated international tax planning, potentially leading to restructuring of foreign subsidiaries or a re-evaluation of where new international ventures are established, to optimize for the new tax landscape.

I. AI, Supply Chain & Domestic Sourcing Mandates: Aligning Capital with National Priorities

The OBBBA makes substantial federal investments in U.S.-based AI infrastructure and R&D, including significant funding for data centers, semiconductor manufacturing, and AI research.11 However, access to these funds, grants, and tax incentives is tightly conditioned on strict domestic content rules and explicit prohibitions on involvement by "prohibited foreign entities".11 These "foreign entities of concern" (FEOC) are specifically identified as those from countries such as China, Russia, North Korea, or Iran.11

Key provisions include stringent restrictions on foreign influence in the AI supply chain, broad extraterritorial rules targeting prohibited foreign entities, enhanced domestic sourcing mandates, and rigorous supply chain integrity requirements.11 Specific funding allocations underscore this commitment, with billions directed towards various initiatives: $450 million for AI in naval shipbuilding, $124 million for Test Resource Management Center AI capabilities, $145 million for unmanned aerial systems and naval systems AI development, $250 million for AI ecosystem advancement, $250 million for Cyber Command AI, $200 million for DOD audit automation, $115 million for NNSA AI, $6.168 billion for CBP border technology including AI, and $150 million for the Department of Energy to curate scientific data for next-generation microelectronics and AI models.12 The bill also imposes new restrictions on certain foreign entities constructing and owning clean energy facilities, prohibiting taxpayers from claiming several energy credits if they have ties to these prohibited foreign entities.13

The OBBBA's AI, supply chain, and domestic sourcing mandates are not merely economic policies but represent a significant geopolitical strategy. By tying federal funding and tax credits to strict domestic content rules and prohibiting "foreign entities of concern," the U.S. government is actively de-risking its critical supply chains and fostering technological independence, particularly from geopolitical rivals.11 For family offices, this means that investments in compliant U.S. companies are not only financially incentivized but also carry the implicit backing of a national strategic imperative. This can lead to more stable and potentially protected markets for these businesses, influencing long-term capital allocation decisions towards "friend-shoring" or "ally-shoring" strategies.

The strict due diligence requirements regarding beneficial ownership and supply chain integrity introduce a new dimension to investment analysis. It is no longer sufficient to solely assess a company's financial health and market potential. Investors must now rigorously verify its supply chain origins and ownership structure to ensure eligibility for OBBBA benefits and avoid potential penalties.11 This necessitates specialized expertise in supply chain mapping, beneficial ownership analysis, and geopolitical risk assessment. Family offices may need to build internal capabilities or rely on external advisors with deep knowledge in these areas, transforming investment due diligence into a more complex, compliance-driven process.

J. Shift in Clean Energy Incentives: Re-evaluating Investment Focus

The OBBBA signals a notable shift in federal clean energy incentives, with many renewable tax benefits (such as those for solar and electric vehicles) being phased out or sharply curtailed.10 While the OBBBA extends the Section 45Z clean fuel production credit and makes changes to the Section 45X advanced manufacturing production credit, it also expedites phaseouts and credit termination dates for primarily wind, solar, electric vehicles, and residential energy property.10 Furthermore, new restrictions are imposed on certain foreign entities constructing and owning clean energy facilities, prohibiting taxpayers from claiming several energy credits if they have ties to these prohibited foreign entities.10

  • Family Office Angle:
  • This shift necessitates a re-evaluation of investment strategies that were heavily focused on IRA-era clean energy targets. While significant incentives remain for the clean fuels industry and other clean energy sources like geothermal, hydropower, nuclear, fuel cell, and energy storage 10, family offices should adjust their due diligence to understand the new eligibility criteria and potential phase-outs for specific technologies. This may involve shifting attention to areas where incentives remain strong or where the market dynamics are less reliant on federal tax credits.

IV. Holistic Wealth Management in the OBBBA Era

The interconnected provisions of the OBBBA necessitate a holistic review of a family's entire financial ecosystem. Changes in one area, such as immediate R&D expensing for a portfolio company, can have ripple effects on others, influencing the overall income tax posture and enhancing the potential for QSBS benefits upon exit. This environment demands a strategic alignment of investment decisions with comprehensive tax planning. For instance, leveraging enhanced QSBS benefits for growth equity alongside Opportunity Zones for real estate gains, while simultaneously optimizing R&D expensing for operating businesses, creates a powerful synergistic effect. Revisiting existing trust structures and gifting strategies in light of the increased estate and gift tax exemptions is also crucial to ensure maximum efficiency and flexibility for intergenerational wealth transfer.

The OBBBA provisions create a complex, but highly synergistic, environment where tax planning is no longer a separate function but an integral part of investment strategy. For example, investing in a QSBS-eligible company 5 that also qualifies for R&D expensing 6 and is located in an Opportunity Zone 6 creates a powerful compounding effect of tax advantages. Family offices must now actively seek out these multi-qualified opportunities. This requires a highly integrated advisory approach where tax, investment, and legal teams collaborate closely to identify and execute optimal strategies, moving beyond siloed decision-making.

The OBBBA's incentives for domestic manufacturing, R&D, and AI could lead to a "domestic premium" in the valuation of U.S.-based companies that align with these priorities.7 Companies that can leverage the OBBBA's tax credits, deductions, and federal funding will gain a competitive advantage due to lower operating costs and potentially higher profitability. This enhanced financial profile could translate into higher valuations in fundraising rounds and M&A activities. Family offices should factor this "domestic premium" into their investment theses, recognizing that adherence to domestic sourcing and foreign entity restrictions 11 can directly enhance returns.

The complexity of provisions like AI/supply chain mandates and FDII changes highlights the need for advisors who bridge technological understanding with tax expertise.9 Evaluating investments in AI, semiconductors, or complex supply chains now requires understanding not just the technology itself, but also the intricate web of domestic content rules, foreign entity restrictions 11, and the implications of international tax changes.9 A traditional tax advisor might miss the technological nuances, and a tech expert might overlook the tax implications. Family offices will increasingly seek integrated advisory services that can navigate both the technical and fiscal landscapes simultaneously, ensuring compliance and maximizing benefits.

While the OBBBA strongly incentivizes domestic investment, market observers suggest that these trends may simultaneously reinforce the growing importance of geographic diversification and currency exposure management for overall portfolio resilience.6 The shift in international tax rules (FDII/GILTI changes) and the introduction of foreign entity restrictions (AI/supply chain) also necessitate proactive risk mitigation strategies for global investments and operations.6 Furthermore, the increased estate tax exemptions may empower families to prioritize their charitable goals more effectively 5, and Opportunity Zones continue to offer a compelling avenue for aligning capital with broader social impact objectives.15

Specific Asset Considerations: Private Jets and 100% Bonus Depreciation

The OBBBA's restoration of full 100% bonus depreciation for qualified property placed in service after January 19, 2025 6, extends to certain high-value assets, including aircraft used for business.

  • What Changed:
  • Under Section 168(k), new and used private aircraft can qualify for 100% bonus depreciation if they are:
    • Used primarily for business (more than 50%).
    • Placed into service in the tax year.
    • Not used predominantly outside the U.S.
  • Impact for Family Offices:
  • A significant investment, such as a $30 million private jet, if used for qualifying business purposes, could allow for a $30 million first-year write-off. This substantial deduction can be strategically used to shelter gains from other parts of the portfolio, such as the sale of a business, private equity exits, or carried interest.
  • Critical Assumptions & Skeptical View:
    • Material Participation: To qualify for this benefit, the family office or its related entity must materially participate in the business activity for which the aircraft is used, or lease it to an active business.
    • Personal Use: If personal use exceeds 50%, the aircraft is disqualified from bonus depreciation.
    • IRS Scrutiny: It is crucial to understand that private jet deductions are often a "red flag" for IRS audits. Therefore, the business use must be meticulously documented, consistent, and legally defensible. Family offices should not assume they can purchase a jet personally and claim the write-off; the correct entity structure, typically an operating LLC or a management company that charters the aircraft for business, is essential.

V. Conclusion: Proactive Engagement for Enduring Advantage

The One Big Beautiful Bill Act represents a profound and enduring shift in the U.S. economic and tax landscape. It offers unprecedented opportunities for wealth creation, preservation, and intergenerational transfer, while simultaneously directing capital towards strategic national priorities such as innovation, domestic manufacturing, and critical supply chains. The permanence of many provisions, including Opportunity Zones, individual tax rates, QSBS benefits, and R&D expensing 5, signals a stable, long-term framework for investment. This stability reduces regulatory risk and encourages long-term capital commitments, particularly in areas like domestic manufacturing and innovation. It means that the strategic advantages derived from the OBBBA are not fleeting but can be integrated into multi-generational investment planning, providing a durable competitive edge.

Family offices and HNWIs are strongly urged to undertake an immediate and comprehensive review of their current tax posture, investment strategies, and estate plans.5 Engaging with seasoned tax attorneys, wealth managers, and investment advisors is paramount to fully understand the nuanced implications of the OBBBA's provisions and to craft tailored strategies that maximize benefits and mitigate risks. The dynamic legislative environment and the specific deadlines embedded within the OBBBA, such as the requirement for Opportunity Zone gain recognition by the end of 2026 and the semiconductor credit construction deadline by the end of 2026 6, underscore the critical importance of proactive and agile decision-making.

The complexity of the OBBBA elevates the importance of sophisticated, either in-house or outsourced, family office capabilities. Navigating the OBBBA's implications across tax, investment, estate planning, and even geopolitical considerations requires a level of expertise and coordination that goes beyond traditional wealth management.11 Family offices will increasingly need to function as strategic hubs, integrating insights from various specialists to optimize their overall financial and legacy objectives. By strategically aligning capital with the OBBBA's incentives, family offices and HNWIs can not only enhance their financial outcomes but also contribute significantly to the nation's economic resilience and technological leadership.

About the Author

Steven Saltzstein is the Founding CEO of the FORCE Family Office and a leading Thought Leader to Ultra High Net Worth Individuals and Family Offices worldwide. To schedule a complimentary consultation, contact Steven at This email address is being protected from spambots. You need JavaScript enabled to view it.

Works cited

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  3. (GEN-25-04) Federal Student Loan Program Provisions Effective Upon Enactment Under the One Big Beautiful Bill Act - FSA Partner Connect, accessed July 21, 2025, https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2025-07-18/federal-student-loan-program-provisions-effective-upon-enactment-under-one-big-beautiful-bill-act
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  6. Key OBBBA implications for family offices, high-net-worth investors, accessed July 21, 2025, https://www.mwe.com/insights/key-obbba-implications-for-family-offices-and-high-net-worth-investors/
  7. S. export controls + semiconductor tax incentives - Sourceability, accessed July 21, 2025, https://sourceability.com/post/us-export-controls-semiconductor-tax-incentives
  8. The New Tax Law: Discover the Many Benefits for Manufacturers, accessed July 21, 2025, https://www.claconnect.com/en/resources/blogs/manufacturing/the-new-tax-law-discover-the-many-benefits-for-manufacturers
  9. International tax reform under the One Big Beautiful Bill Act - RSM US, accessed July 21, 2025, https://rsmus.com/insights/services/business-tax/international-tax-reform-under-the-one-big-beautiful-bill-act.html
  10. International Tax Changes in the One Big Beautiful Bill Act - Steptoe, accessed July 21, 2025, https://www.steptoe.com/en/news-publications/international-tax-changes-in-the-one-big-beautiful-bill-act.html
  11. AI and Tech under the One Big Beautiful Bill Act: Key Restrictions, Risks, and Opportunities, accessed July 21, 2025, https://www.ropesgray.com/en/insights/alerts/2025/07/ai-and-tech-under-the-one-big-beautiful-bill-act-key-restrictions-risks-and-opportunities
  12. Updated: AI Provisions in the One Big Beautiful Bill Act - Akin Gump, accessed July 21, 2025, https://www.akingump.com/en/insights/ai-law-and-regulation-tracker/updated-ai-provisions-in-the-one-big-beautiful-bill-act
  13. Tax bill significantly changes clean energy credits and incentives | RSM US, accessed July 21, 2025, https://rsmus.com/insights/services/business-tax/obbba-tax-clean-energy.html
  14. The OBBBA expands QSBS exclusions: What it means for businesses and investors, accessed July 21, 2025, https://rsmus.com/insights/services/business-tax/obbba-tax-qsbs.html
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