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Course Details

This CLE webinar will address the One Big Beautiful Bill Act's (OBBBA) 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

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 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 treatment of capital expenditures, and expanded tax benefits for domestic investments. Some key provisions OBBBA provides for private equity include expansion of qualified small business stock (QSBS) exclusion, expansion of capital gains exclusion, relaxed limitation on deductibility of business interest, qualified business income deduction, expansion of bonus depreciation, and deductibility of fund management fees. 

There were a few key proposals that did not make it into the final Act, leaving what is viewed as a more favorable tax regime in place for private equity funds, sponsors, and investors. The notable omissions include no carried interest provision, no change to the capital gains tax rate, and no "retaliatory tax" on certain foreign investors. 

Listen as our authoritative panel discusses the important private equity implications of OBBBA and business and investment strategies private equity funds, investors, and portfolio companies may want to consider to take advantage of these new tax incentives and credits.

Outline

I. Introduction: OBBBA overview and history

II. OBBBA's implications for private equity funds, investors, and portfolio companies

A. Enhanced qualified small business stock benefits

B. Expansion of capital gains exclusion

C. Relaxed limitation on deductibility of business interest

D. Qualified business income deduction

E. Expansion of bonus depreciation

F. Deductibility of fund management fees

G. Other changes impacting private equity

III. Notable provisions excluded from the final Act

A. No change in taxation of carried interest

B. No change to the capital gains tax rate

C. No retaliatory tax on certain foreign investors

IV. Best practices for guiding clients on the new requirements

V. Practitioner takeaways

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?