INSIGHTS
2025 End-of-Year Tax Update from Aprio
by Aprio
ARTICLE | October 28, 2025
The One Big Beautiful Bill (OBBB), enacted on July 4, 2025, is shaking up the tax world for everyone, from businesses focused on growth to families planning for their future.
Why does this matter?
Tax laws are rarely static. They are constantly evolving, bringing new regulations, opportunities, and responsibilities, some temporary and some permanent. While much remains up in the air, what is clear as 2025 comes to a close is that the tax landscape is more complex than ever before.
In Aprio’s 2025 year-end tax update, we break down the most notable twists and shifts in federal, state, and international taxes impacting businesses and individuals.
01 - Business Tax
Business tax strategy is undergoing significant changes since the passing of the OBBB, empowering business owners with 100% bonus depreciation, expanded opportunities in R&D expensing, and increased Section 179 limits. In addition, the QSBS exclusion has been raised, opening doors for broader eligibility.
QSBS cap rises to $15M
02 - Individual Tax
Several favorable provisions impacting individuals from the TCJA have been made permanent or were expanded with the passage of the OBBB. New tax-saving opportunities were also introduced, notably the new deduction for qualified tips and overtime compensation.
$25,000 deduction for qualified tips and overtime earners
03 - Estate & Gift Tax
The OBBB permanently extended the estate and gift tax exemption, raising the federal lifetime exemption to $15 million for tax years starting after December 31, 2025. Strategic planning will be essential to maximize this tax advantage. Addressing non-tax concerns, such as asset protection, healthcare directives, guardianship, and business succession will be key.
Estate and gift tax exemption raised to $15M permanently
04 - International Tax
International tax laws are evolving amid rapid globalization and digital transformation. The OBBB, new treaties, and the landmark ruling in Facebook, Inc. v. Commissioner have ushered in stricter rules for profit-shifting, transfer pricing, and foreign tax credits. Other notable changes businesses must be aware of include the Belarus treaty suspension, clarified PTEP regulations, and reduced GILTI (now NCTI) deduction rates.
New rules & treaties reshaping international tax
05 - Tariffs
President Trump’s 2025 global tariffs, imposed under the IEEPA, have sparked constitutional challenges and divided courts, with the Supreme Court set to decide their fate. If overturned, billions in refunds may be issued to U.S. businesses, while upholding them would require ongoing adaptation. The ruling will profoundly impact trade policy, business costs, and the broader economy, making close monitoring essential for all stakeholders.
The Supreme Court will decide the fate of U.S. trade policy
06 - State and Local Tax
The OBBB sparked changes in state and local taxation (SALT) rules, especially after raising the SALT deduction cap to $40,000 through 2029. Despite uncertainty on expiration dates, states have begun responding by expanding pass-through entity tax (PTET) programs. Varied approaches to federal conformity and evolving rules for bonus depreciation, net operating losses, and income apportionment reflect a complex shift in the SALT landscape.
SALT cap rises to $40,000 through 2029
07 - Employment Tax
The OBBB and evolving IRS guidance has made year-end employment tax compliance increasingly complex. Notable changes impacting business and individuals include permanent credits for family and medical leave, new rules for overtime and tips, and a heighted focus on state tax obligations.
New provisions impact FMLA, tips and overtime & SUI taxes
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This article was written by Aprio and originally appeared on 2025-10-24. Reprinted with permission from Aprio LLP. © 2025 Aprio LLP. All rights reserved. https://www.aprio.com/2025-end-of-year-tax-update/
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