Top 5 Year-End Tax Planning Moves Before 2026: What Businesses & Individuals Should Know

Dec 01, 2025

As we approach the end of the year—and as major tax law changes begin to take effect—it’s critical for both businesses and individuals to take stock of evolving tax provisions. The recent updates from the 119th Congress, as detailed in William Vaughan Company’s 2025 Year-End Tax Planning Webinar, contain significant opportunities and pitfalls. Smart planning now can unlock growth, mitigate risks, and ensure you’re maximizing every available benefit.

Below, we break down the top 5 tax planning considerations you should address before 2026:

1. Leverage Bonus Depreciation and Expensing Changes – for businesses:

  • Immediate expensing is available for property with a class life of 20 years or less, placed in service after January 19, 2025.
  • Qualified Production Property: Eligible manufacturers who place qualifying real property in service between July 4, 2025 and December 31, 2030, may benefit from accelerated depreciation on this property. This property must meet several specific requirements in order to qualify.
  • State Tax Considerations: For certain states (Michigan in particular), Individuals and flow-through entities must use IRC rules as of 12/31/24 for bonus depreciation, which continues the planned phase-outs and limitations as outlined in the Tax Cuts and Jobs Act of 2017.

Action Step: Review capital expenditure plans now. Accelerate purchases or construction to maximize deductions under the current, more favorable rules.

2. Prepare for Beneficial Changes to Interest Expense Limitations
What’s changing:

  • Starting January 1, 2025, businesses subject to Section 163(j) interest expense limitations can calculate their amount of limited interest expense based on their EBITDA. Previously, Depreciation & Amortization could not be added back in this calculation, which resulted in less allowed interest expense.
  • Starting January 1, 2026 any interest capitalized as additional tax basis to an asset must be broken out of that assets depreciation and subjected to the 163(j) limitations as if it were not part of depreciation.
  • Michigan businesses: Recent decoupling from federal rules means separate treatment for business interest deductions.

Action Step: Conduct a Section 163(j) analysis to determine if upcoming changes in the limitations will impact your financing structure or projected taxable income.

3. Understand and Optimize Research & Experimental Expenditures (Section 174)
Significant changes to Section 174, governing Research and Experimental (R&E) expenditures, have a direct impact on businesses engaged in innovation, product development, or process improvement. Here’s what you need to know:

Recent Legislative Updates

  • Pre-2022: Businesses could elect to deduct R&E expenses in the year incurred.
  • 2022–2024: R&E costs had to be capitalized and amortized (generally over five years for domestic and fifteen years for foreign expenditures).
  • Post-2024 (Starting in 2025): Businesses may once again elect to deduct R&E expenses in the year incurred (except foreign expenses, which remain subject to 15-year amortization)

Strategic Planning Opportunities

  • Previously Amortized Costs Going Forward:
    • For 2025, all businesses can elect to expense all prior years unamortized R&E costs in the current year or choose to expense half in 2025 and the remaining half in 2026.
    • If your business has less than $31 million in gross sales on average over the last 3 years, the new law allows for amending prior returns. I.e. you may go back and expense R&E costs in the year they were incurred and claim refunds. The deadline to amend these returns is generally by July 6, 2026, a much shorter timeframe than typically allowed for amendments.
  • Michigan Decoupling:
    • The state now decouples from federal rules on Section 174A (R&E expenses), in addition to Section 163(j), Section 179, and bonus depreciation provisions (Sections 168(n) & 168(k)), after Michigan’s latest budget package passed (H.B. 4961, signed 10/7/25).

Action Steps for Businesses

  • Review your current and planned R&E activities.
    • Evaluate whether you should accelerate R&E spending into 2025 to maximize immediate deductions.
    • Determine if you are eligible to amend prior year returns and evaluate whether you should do so, in order to meet the fast-approaching deadline.
    • Coordinate with tax advisors to track eligible expenditures and ensure compliance with both federal and state rules.
  • Individuals & Flow-Through Entities:
    • Between section 174A, 163(j) and 168(k) taxable income may be down in 2025 compared to prior years. If you are an S-Corporation, be sure to consider your stock basis and the deductibility of losses when making key decisions for 2025.
    • Also consider making a Roth conversion to take advantage of lower tax brackets if income is lower due to 2025 tax law changes.

4. Maximize Individual Deductions and Credits Before Phase-outs
Standard deduction increases (effective 2025):

  • Single: $15,750
  • Married Filing Jointly: $31,500
  • Additional $6,000 for taxpayers 65+ (phase-outs apply).

Other highlights:

  • State and Local Tax (SALT) cap: $40,000 for 2025-2029, then drops to $10,000 in 2030 (phase-outs apply).
  • Mortgage insurance premiums: Deductible from 2026.
  • Charitable deduction for non-itemizers: Up to $2,000 for joint filers from 2026.
  • Child Tax Credit: Increased and inflation-adjusted.
  • Charitable donations for itemizers: Deductions will be limited for taxpayers in the maximum tax bracket of 37% at 35%. Donations will also be subject to a floor of 0.5% of the taxpayers taxable income beginning in 2026.

Action Step: Bunch deductions: Consider timing charitable giving, SALT payments, and other deductions to optimize their tax impact before stricter caps and limitations set in. Consider making large doner advised fund (DAF) donations in 2025 to take advantage of the deductions before the new limitations take effect.

5. Estate & Gift Tax Planning

  • Exemption increases to $15M in 2026 (from $13.99M in 2025).
  • Annual gifting limit: $19,000 in 2025, inflation-adjusted for 2026.
  • Portability remains for spouses.

Action Step: Review your estate plan: High-net-worth individuals should review gifting strategies and trusts now that we have some certainty in the annual and lifetime limits.

Why Proactive Planning Matters
With so many provisions phasing in and out, proactive tax planning is essential. The coming years will see the continuance of many prominent TCJA provisions, new deductions, and complex interactions between federal and state rules. William Vaughan Company is here to help you navigate these changes, optimize your tax position, and ensure compliance.

Connect with Us.
Ruben Becerra, CPA – ruben.becerra@wvco.com
Chad Gates, CPA – chad.gates@wvco.com

Categories: Tax Planning

New R&E Expenditure Changes Under IRC Section 174 to Begin in 2022

Jan 26, 2022

As 2022 begins, so does the amendment to the Internal Revenue Code (IRC) Section 174, originally introduced by 2017 tax reform legislation, the Tax and Jobs Act (TCJA.)

That amendment requires both US-Based and non US-Based research and experimental expenditures (R&E) for tax years starting after December 31st, 2021 be capitalized and amortized over a period of five or 15 years, respectively.
Previous to the TCJA amendment, taxpayers could elect to either capitalize and amortize R&E expenditures over a period of at least 60 months, or deduct the expenditures in the year paid or incurred, (taxpayers could also choose to make an election under Section 59(e) to amortize expenditures over 10 years.) Under the new legislation, amortization begins at the midpoint of the taxable year in which expenses are paid or incurred, which could create a significant year-one impact.

For example, if a taxpayer incurs $5 million of R&E expenditures in 2022, the taxpayer will now be entitled to amortization expense of $500,000 in 2022. We arrived at this calculated by dividing $5 million by five years, then cutting the annual amortization amount in half. Prior to the TCJA, the taxpayer would have immediately expensed all $5 million on its 2022 tax return, assuming it did not make an election under Section 174(b) or Section 59(e) to capitalize the amounts.

Additionally, software development costs have been added as R&E expenditures under Section 174(c)(3) and, therefore, are also subject to the same mandatory amortization period of five or 15 years. Previously, under Rev. Proc. 2000-50 options existed for taxpayers to either expense software development costs as they incurred, amortize over 36 months from the date the software was placed in service, or amortize over not less than 60 months from the date the development was completed.

Immediate Considerations
Under the new Section 174 requirements, taxpayers should ensure that all R&E expenditures are properly identified, as some may be able to leverage from existing systems/tracking to identify R&E. Taxpayers that have existing systems in place to calculate the research credit will likely be able to use such computations as a helpful starting point for determining R&E expenditures. By definition, any costs included in the research credit calculation would then need to be recovered under the five-year amortization period.

Taxpayers currently not identifying any R&E expenditures should consider the steps necessary to assess the amount of their expenditures that are subject to Section 174. Under some circumstances, it may be wise to begin separating out R&E expenditure amounts to their own trial balance accounts, e.g. to have a separate “trial balance account” for R&E expenditure wages versus non-R&E wages. Determining which costs should be included in the relevant R&E expenditure trial balance accounts will likely involve interviews with the taxpayer’s operation and financial accounting personnel, as well as the development of allocation methodologies that determine which expenses (e.g., rent) relate to both R&E expenditure and non-R&E expenditure activities.

Additional Effects of Section 174 Amendment
It should be noted that under Section 174, the types of expenses eligible for duction are generally broader than those expenses eligible for credit under Section 41. For example, Section 41 allows supplies, wages and contract research, while Section 174 can include items such as utilities, depreciation, attorneys’ fees and other expenditures related to the development or improvement of a product.

Key Take-Aways
The implemented changes of Section 174 may bring some potentially favorable tax developments for those previously employing the capitalization of R&E expenditures. With the new amendment allowing for amortization of R&E expenditures at the midpoint of the fiscal year they were incurred, certain taxpayers may be able to recoup those costs sooner.

It should also be noted that the language in the TCJA indicates that the Section 174 amendment should be treated as a “change in method of accounting” and applies on a cut-off basis beginning for tax year 2022. Any costs incurred before 2022 will remain as-is and fall under the previous rules mentioned above. It is still unknown if taxpayers that previously expensed their R&E expenditures will have to file an “Application for Change in Method of Accounting (Form 3115).”

The IRS is expected to release guidance on how taxpayers should comply with the new rule for the 2022 tax year, presuming the start-date of the provision is not again postponed by Congress. Because of this and other areas of uncertainly surrounding the new amendment, taxpayers should continue to monitor IRS and Treasury updates, or consult with their William Vaughan advisor before filing any 2022 tax returns in order to ensure compliance with the latest regulations.

Connect with Us.

Robert Bradshaw, CPA

Tax Partner

bob.bradshaw@wvco.com | 419.891.1040

Categories: Tax Planning