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The Unclaimed Dividend

OBBBA Capital Tax Benefits Research

The One Big Beautiful Bill Act handed capital-intensive companies the most generous cost recovery regime in modern tax history: permanent 100% bonus depreciation, first-ever full expensing for production facilities, and the return of EBITDA to the interest deduction limit. Fifteen months later, the deductions are being claimed. The value is not. The leakage happens long before the tax return, inside capital planning and financing decisions that still treat tax as a year-end calculation.

61%

of available OBBBA acceleration value captured by mid-sized and large companies in 2025 capital spending

$740K

Median value left unclaimed per company among firms spending $20M+ a year on CapEx (median spend: $42M)

Fewer than 1 in 5

manufacturers with qualifying construction underway have done the work to support a production facility expensing election

44%

of leveraged companies carrying disallowed interest have not re-modeled capacity under the restored EBITDA base

Our new cross-sector research examines where the OBBBA benefit is escaping, and the answer is uncomfortable: not on the return, but in the decisions made before anyone in tax sees the deal. Roughly two in three equipment structuring decisions happen before the tax function is consulted. Companies are acquiring assets under contracts signed before the January 2025 cutoff, building plants without the documentation facility expensing requires, carrying elections made under the old interest rules that now block the biggest incentives in the law, and generating deductions they cannot absorb because of losses and carryforwards. Capture ranges from roughly seven in ten dollars in business aviation to under half in mining, with data centers, marine, and manufacturing in between. A lower interest rate cannot fix any of it. A lender that closes after December 31 pushes the deduction into next year, and a loan that leaves the deduction with an owner who cannot use it lets it erode as a carryforward. Under a regime this generous, the true cost of capital is the rate minus the tax value you actually capture.

IN THIS REPORT:

  • Three Provisions, One Capital Thesis: Bonus Depreciation, Qualified Production Property, and the 163(j) EBITDA Restoration
  • Why Permanence Bred Complacency: How the End of the Phase-Down Erased the Planning Discipline
  • Where the Value Is Leaking: Capture Rates Across Manufacturing, Oil & Gas, Aviation, Private Equity, Data Centers, Mining, and Marine
  • The Capture Constraint: Tax Appetite, Legacy Elections, Acquisition Dates, QPP Documentation, and the Year-End Calendar
  • Structuring for Capture: Matching Ownership of Every Asset to the Party That Can Use Its Depreciation
  • Strategic Implications for CFOs, PE Operating Partners, and Tax Directors

The benefits are being claimed in form and forfeited in substance. In a regime this generous, the cost of capital is no longer the rate. It is the rate minus the tax value you actually capture.

Download the Research and Analysis

This report examines why mid-sized and large companies are capturing only part of the capital investment value created by the One Big Beautiful Bill Act, and what separates the companies capturing all of it. Includes capture-rate estimates across seven capital-intensive sectors, findings from 612 surveyed finance decision-makers, worked examples covering facility expensing, interest capacity, purchase price allocation, and year-end timing, and a framework for matching ownership and financing structure to tax capacity through residual-based leases, sale-leasebacks, and lifecycle capital planning.

Explore the Implications

Dive deeper into specific findings from our capex research with our thought leadership series:

First National Capital: Your Partner in Strategic CapEx Finance

The OBBBA capture gap is not a tax compliance problem. It is a capital structure problem. Traditional lenders price your credit and fund on their committee calendar; they are indifferent to which year your deduction lands in and to whether you can use the depreciation on the assets they finance. First National Capital starts with the questions that now determine what capital actually costs: who should own each asset, when it needs to be in service, and how the structure affects the next decision.

Our team works with CFOs, operating partners, and owners to build financing strategies matched to tax capacity, asset characteristics, and the calendar. We specialize in:

  1. Closing equipment financing in weeks, not the 73-plus days typical of bank committees, so assets are placed in service in the tax year your plan requires
  2. Structuring residual-based leases that place depreciation with a party that can use it now when losses, carryforwards, or pass-through limits mean you cannot
  3. Executing sale-leasebacks that convert equipment acquired during loss years into liquidity for growth, add-ons, or recapitalizations without dilution
  4. Financing equipment inside new production facilities so owners can keep the building, and its full expensing election, on their own balance sheet
  5. Supporting platforms and multi-entity companies with financing across portfolio companies and add-ons, sequenced against combined tax capacity

With over $4.5 billion deployed across North America, First National Capital has the expertise, capacity, and execution speed to serve as a genuine strategic partner—not merely a transactional vendor.

Flexible Terms

  • Transaction sizes from $500M to $100MM+
  • Terms from 24 to 180 months depending on assets financed
  • Amortizations up to 20+ years
  • No Covenants
  • Flexible collateral requirements
  • Risk-based pricing yielding competitive rates for strong and challenged-credit

Finance Structures

  • Sale Leaseback
  • Loans & Capital Leases
  • Project Finance
  • Seasonal, Step-Up & Skip Payments

It All Begins With A Conversation About Capital Needs

We listen. We live out-of-the-box. We solve problems. And we get deals done.  Let’s do this.