A deduction is only worth what it saves. For capital-intensive operators carrying losses, the most celebrated provision in the OBBBA is a slow-motion write-down.

Worthless overstates it. Not by as much as you would think.

When the One Big Beautiful Bill Act restored permanent 100% bonus depreciation, the headlines treated it as a universal gift to capital-intensive industry. Buy equipment, deduct it immediately, keep the cash. For a company with steady taxable income, that is exactly what it is.

But the most capital-intensive businesses in America are often the ones least able to use it. Data center developers in growth mode, mining operators coming out of a down cycle, and marine fleets held in family pass-through structures generate depreciation far faster than they generate taxable income. For them, a 100% deduction is not cash. It is a number on a carryforward schedule, and it loses value every year it waits.

Our research estimates that data center operators captured about 51% of the OBBBA acceleration value available on 2025 spending, mining operators about 49%, and marine operators about 53%. Those are the lowest capture rates of any segments we studied, and the reason is not a lack of sophistication. It is a lack of appetite.

What a Carryforward Really Costs

Consider a data center operator that places $50 million of electrical, mechanical, and IT infrastructure in service this year. That deduction is worth $10.5 million in federal tax. If the company is profitable, it saves that $10.5 million now.

If the company is still in its build-out phase and will not have meaningful taxable income for four years, the deduction becomes a net operating loss. Post-2017 losses can offset only 80% of taxable income in any year, so recovery stretches further. If that operator finally uses the benefit across years five and six, its present value at an 8% discount rate falls to under $7 million. Roughly $3.5 million, about a third of the benefit, evaporates simply by waiting.

And data center operators rarely wait for just one asset. Servers and network equipment refresh on three- to five-year cycles, which means the next round of deductions arrives before the last one has been used. The carryforward grows faster than the business can consume it.

Why Each Segment Is Stuck

Data centers face a compounding problem. Electrical switchgear, UPS systems, generators, cooling plants, and IT equipment can represent 60% to 80% of project cost, nearly all of it bonus-eligible. The building shell does not qualify for the new production facility deduction because data processing is not a qualified production activity. And several states with heavy data center concentration have decoupled from federal bonus depreciation entirely, so the state benefit many models assume does not exist.

Mining operators carry the cycle on their balance sheets. Haul trucks priced from $3 million to $6 million, loaders, drills, and processing equipment all qualify for bonus, but extraction itself does not qualify for production facility expensing, and many operators emerged from recent downturns with significant losses still on the books.

Marine operators, including inland towboat and barge fleets, are frequently owned through partnerships and S corporations. The losses flow through to individual owners, where the excess business loss limitation, which the OBBBA made permanent, caps how much business loss can offset other income each year. Owners who do not materially participate face passive activity limits on top of that. The depreciation exists. The capacity to use it does not.

The Default Nobody Chose

Here is what most of these operators will not hear from their lenders. Owning assets you cannot depreciate efficiently is a choice. Most companies make it by default, because their bank offers one structure: a loan that leaves the borrower owning the asset and holding the deduction.

A bank has no reason to care whether you can use the depreciation on equipment it finances. Its credit process evaluates your ability to repay. Whether the 100% deduction becomes cash or a decaying carryforward is your problem, not its.

It should be someone’s problem, because the solution is well established. When an operator lacks tax capacity, a lease places ownership of the asset, and its depreciation, with a lessor that can use it now. A lessor with real expertise in the equipment, one that can set a residual value based on how that switchgear, haul truck, or towboat actually holds value in its specific application, can return a substantial share of the tax benefit through lower payments.

For assets acquired during loss years, when the depreciation produced little value, a sale-leaseback can go further. The operator sells equipment to an unrelated lessor and continues operating it without interruption. Gain on the sale may be absorbed by existing losses. The lessor takes a fresh tax basis that can qualify for bonus depreciation. The operator receives liquidity it can put back into growth, at a cost that is typically far below its cost of equity.

No lessor gives away the entire benefit. But sharing a deduction that is worth 21 cents on the dollar today is a better outcome than owning one that is worth about 14 cents five years from now.

The Real Question

The debate in capital-intensive industries is usually framed as own versus lease, and it is usually settled on rate. That framing misses the point. The real question is which party can use each deduction today, and whether your capital structure puts it there.

The OBBBA made depreciation more valuable than at any time in modern tax history. It did not make it equally valuable to everyone. The operators who recognize that will build the same data centers, run the same fleets, and mine the same reserves at a structurally lower cost than the ones who do not.