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New Research Finds Mid-Sized Companies Are Capturing Only 61% of OBBBA Capital Investment Tax Benefits

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New Research Finds Mid-Sized Companies Are Capturing Only 61% of OBBBA Capital Investment Tax Benefits

First National Capital Corporation, one of the largest independent providers of capital equipment and project financing in North America, today released The Unclaimed Dividend, a cross-sector research report examining how mid-sized and large companies are using the capital investment provisions of the One Big Beautiful Bill Act (OBBBA). The research finds that companies captured an estimated 61% of the value these provisions made available on 2025 capital spending, measured as the present value of federal tax savings the OBBBA adds over prior cost recovery rules at a 21% rate and 8% discount rate. Among firms with $20 million or more in annual CapEx, where median spending is about $42 million, that leaves a median of roughly $740,000 a year unclaimed.

The report focuses on the three OBBBA provisions with the greatest impact on capital-intensive businesses: permanent 100% bonus depreciation; the new 100% expensing election for qualified production property; and the restoration of EBITDA as the base for the business interest limitation under Section 163(j).

Among the key findings: fewer than one in five manufacturers with qualifying construction underway have completed the space-level analysis needed to support a production property election. Some 44% of leveraged companies carrying disallowed interest have not re-modeled their interest capacity under the restored EBITDA base. And roughly two in three equipment structuring decisions are made before the company’s tax function is consulted.

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Capture rates varied sharply by industry. Business aviation buyers captured an estimated 71% of available value, while oil and gas operators captured 66%, private equity portfolio companies 60%, and manufacturers 57%.


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