OBBBA Compliance Review Checklist for 2026: What CEOs and CFOs Should Double-Check Before Filing

OBBBA Compliance Review Checklist for 2026: What CEOs and CFOs Should Double-Check Before Filing

The success of your business relies on staying compliant with complex and continually evolving tax laws, including the recently passed One Big Beautiful Bill Act (OBBBA).

Signed into law in July of 2025, the bill makes permanent many of the temporary provisions included in the 2017 Tax Cuts and Jobs Act (TCJA) and introduces new provisions geared toward strengthening the U.S. economy. Included among them are numerous provisions designed to help corporate taxpayers ease their tax burden, simplify financial reporting, and improve cash flow going forward—provided they have a clear tax strategy in place.

With key provisions already in effect and others taking effect soon, business leaders should work closely with their tax advisory teams prior to the upcoming tax filing deadline to ensure compliance as well as prepare for the 2027 filing season. The following is an overview of key OBBBA reporting changes and deduction updates that will impact business owners, including a compliance review checklist to help you prepare for April.

Key Changes for Corporate Taxpayers

Effective Immediately:

Form 1099-K Threshold Change

Form 1099-K reports credit, debit, and gift card transactions as well as payments from apps and online marketplaces (third-party settlement organizations) such as Apple Pay, PayPal, Venmo, and Zelle. Under OBBBA, the reporting threshold for Form 1099-K returns to $20,000 in payments and at least 200 transactions for the 2025 tax year and beyond, which is what it was before the American Rescue Plan Act of 2021 was enacted. Businesses whose payments met the new threshold in 2025 can look forward to receiving a Form 1099-K.

(Note: The new reporting threshold reverses a previously planned and continually delayed phase-in schedule that would have lowered the threshold to $600 with no transaction minimum.)

Reinstatement of 100% Bonus Depreciation

The new law permanently restores 100% bonus depreciation for eligible assets acquired and placed in service after January 19, 2025. In addition, it introduces a new 100% depreciation for qualified production property (QPP) acquired and placed in service after January 19, 2025 and before January 1, 2029. This is a significant tax incentive designed to help businesses lower the cost of upfront expansion and improve cash flow for operational improvements.

Deduction and Credit Changes

OBBBA restores the immediate deductibility of domestic research and experimental (R&E) costs beginning in 2025, reversing a previous requirement under the TCJA that required businesses to capitalize and amortize the expenditures over a five-year period. The change is a positive one for businesses focused on innovation, research, and development.

With the passage of OBBBA, two key changes were also made to Section 179 of the tax code. First, the expense limit increased from $1.25M to $2.5M, meaning taxpayers can immediately deduct 100% of up to $2.5M in property purchases (including machinery, equipment, furniture, and business vehicles). Second, the phase-out threshold increased from $3.13M to $4M. Amounts will be adjusted annually for inflation beginning in 2026.

Effective for Tax Year 2026:

Forms 1099-NEC and 1099-MISC Threshold Increase

Businesses that frequently utilize freelancers and independent contractors will be familiar with Form 1099-NEC, which reports nonemployee compensation for services rendered. In contrast, Form 1099-MISC reports other miscellaneous compensation, such as for rent payments, prizes and awards, attorney fees, and medical and health care payments.

Under OBBBA, the reporting threshold for both forms will increase from $600—an amount that has remained unchanged for over half a century—to $2,000 for tax year 2026. (For 2027 and subsequent years, the threshold for both forms will be adjusted for inflation.) The income will still be taxable, but amounts under $2,000 will no longer require a 1099. As a result, employers will be required to issue fewer forms, which may ease the filing burden for many businesses.

New Reporting Rules for Tips and Overtime

Employers whose workers receive tips and overtime will need to pay attention to new reporting rules. For tax years 2025 through 2028, OBBBA allows eligible employees to claim federal income tax deductions for qualified tips income and qualified overtime income. That means more detailed reporting for businesses as well as upcoming changes to payroll return forms for the 2026 tax year, including Form W-2 (you can view a draft of the 2026 form here) and the 1099 forms. (Note: The IRS has designated tax year 2025 as a transition year, and no penalties will be imposed for failure to report qualified tips and overtime separately.)

Compliance Review Checklist

While some changes will take effect sooner than others, you can bet the IRS will be paying close attention to whether or not business taxpayers are complying with the new provisions under OBBBA. Early preparation is essential for ensuring compliance and minimizing risk.

  • Know your deadlines. March 16 and April 15 (depending on your corporate structure) are not the only important dates to remember. Make a note of important deadlines for sending forms to your employees, filing your business tax return, submitting quarterly tax payments, requesting an extension, and IRA and HSA contributions.
  • Get your paperwork in order. Organize all income statements, investment documents, deductible expense receipts, prior tax returns, and other essential records. Verify payer names and TINs to avoid mismatches and subsequent penalties (including backup withholding).
  • Stay informed about OBBBA. The expansive tax reform and spending reconciliation bill will have a significant impact on businesses of all sizes and in nearly every industry. Business leaders should know the major provisions affecting corporate taxpayers and be prepared for upcoming changes.
  • Review your internal systems (and update accordingly). Businesses will want to make sure their internal systems are compliant with new OBBBA requirements. This includes reviewing your payroll systems, documentation processes, and payment platforms to avoid future reporting issues.
  • Adjust your tax strategy accordingly. Work closely with your tax preparer to navigate the evolving changes under OBBBA and understand your reporting obligations. Our team at Landmark CPAs will conduct a thorough compliance review to help you make strategic decisions that will reduce your tax burden and ensure compliance with current tax law.

Looking Ahead to 2026

At nearly 1,000 pages, OBBBA is one of the most extensive tax bills in recent history, comprising countless provisions that will affect your tax and reporting strategy in 2025 and beyond.

The key takeaway for business leaders is that careful planning and attention will be paramount going forward. At Landmark, our business tax services team has the experience necessary to help you successfully navigate current regulatory changes and ensure stronger compliance. Contact us today to learn more about leveraging OBBBA provisions for significant tax savings and long-term business growth.

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