Private Equity and the One Big Beautiful Bill Act: Opportunities and Challenges
Expanded QSBS Exclusion, Relaxation of Limitation on Interest Deductions, Expanded Bonus Depreciation, and More

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Course Details
- smart_display Format
Live Online with Live Q&A
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Banking and Finance
- event Date
Tuesday, September 30, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Live Online
On Demand
This CLE webinar will address the One Big Beautiful Bill Act's (OBBBA or Act) impact on private equity. The panel will highlight the key tax provisions of OBBBA impacting private equity funds, investors, and portfolio companies as well as notable proposals not included in the final Act. The panel will also provide guidance on navigating these changes and requirements going forward.
Faculty

Mr. Farr focuses his practice on federal income and international tax planning for partnerships, corporations, and individuals related to complex domestic and international business transactions across a variety of industries, including the technology, healthcare, real estate, and energy sectors. He advises private equity funds, portfolio companies, and public companies with respect to strategic mergers, acquisitions, and reorganizations. Mr. Farr has significant experience with investment fund formation and structuring matters, advising both fund sponsors and limited partner investors. He has extensive experience advising single family offices and high net worth clients with respect to both strategic internal tax structuring and M&A transactional matters across a number of industries, including sports and entertainment, hospitality, technology, and others.


Ms. Xie advises U.S. and international clients, both public and private, on a broad range of tax matters, including the tax aspects of mergers, acquisitions, reorganizations and other complex business transactions. She routinely represents leading public corporations and private equity firms and their portfolio companies across multiple industries, including consumer products, technology, healthcare, manufacturing and financial services.
Description
On July 4, 2025, OBBBA was signed into law by President Trump. OBBBA permanently extends many provisions of the Tax Cuts and Jobs Act of 2017 (TCJA) that were set to expire at the end of 2025 and made several key tax reforms that will have potentially significant consequences for private equity funds and their sponsors. These changes are generally viewed as favorable for the private equity industry.
Under OBBBA, the private equity industry will potentially have greater tax planning stability, improved tax incentives in respect of capital expenditures, and expanded tax benefits for domestic investments. Some key OBBBA provisions relevant for private equity include expansion of the qualified small business stock (QSBS) exclusion, relaxed limitations on deductibility of business interest, permanent extension of the qualified business income deduction, and expansion of bonus depreciation.
There were also a few key proposals that did not make it into the final Act, leaving what is generally viewed as a more favorable tax regime in place for private equity funds, sponsors, and investors. The notable omissions include no changes to existing "carried interest" rules, no changes to the preferential capital gains tax rate, and no new "retaliatory tax" on certain foreign investors with respect to inbound U.S. investments and financings.
Listen as our authoritative panel discusses the important implications of OBBBA and business and investment strategies private equity funds, investors, and portfolio companies may want to consider to take advantage of these tax benefits.
Outline
I. Introduction: OBBBA overview and history
II. OBBBA's implications for private equity funds, investors, and portfolio companies
A. Enhanced QSBS benefits under Section 1202
B. Relaxed limitation on deductibility of business interest under Section 163(j)
C. Permanent qualified business income deduction under Section 199A
D. Expansion of bonus depreciation benefits
E. Changes implicating cross-border M&A
F. Other changes potentially impacting private equity
III. Notable provisions excluded from the final Act
A. Taxation of carried interest
B. Preferential capital gains tax rate
C. Retaliatory tax on certain foreign investors
IV. Best practices for guiding clients on the new requirements
Benefits
The panel will discuss these and other key considerations:
- What OBBBA provisions impact private equity, and what opportunities and challenges do they present?
- What notable tax provisions relevant to private equity remained unchanged with the recent legislation?
- What are the practical implications of OBBBA on private equity business strategies and investments?
- How can private equity funds, investors, and portfolio companies take advantage of OBBBA's new tax regime?
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