Mid-sized companies are missing 39% of new OBBBA tax benefits, report says

First National Capital Corp. says mid-sized and large companies are capturing only 61% of the capital investment tax value available under the One Big Beautiful Bill Act. The Irvine-based lender says the shortfall stems mostly from capital planning and financing choices, not tax filing errors, leaving about $740,000 a year unclaimed for the median company with $20 million or more in annual capital spending.

Why it matters: - The OBBBA’s capital investment provisions can materially lower the cost of equipment, facilities and project financing for capital-intensive companies. - First National Capital Corp. estimates companies are leaving 39% of available federal tax value on the table, which can change how much capital a business can deploy and how it structures financing. - For firms with $20 million or more in annual CapEx, the median unclaimed value is about $740,000 a year.

What happened: - First National Capital Corp. released The Unclaimed Dividend, a cross-sector research report on how mid-sized and large companies are using the OBBBA’s capital investment provisions. - The report says companies captured an estimated 61% of the value available on 2025 capital spending, measured as the present value of federal tax savings at a 21% tax rate and 8% discount rate. - The report focuses on three provisions: permanent 100% bonus depreciation, the 100% expensing election for qualified production property, and restoration of EBITDA as the base for the Section 163(j) business interest limitation. - The research was fielded from July through September 2026 and drew on inferred survey data and sentiment analysis from 612 finance decision-makers, plus FNCC proprietary transaction data. - The full report is available at the full report.

The details: - Among manufacturers with qualifying construction underway, fewer than one in five have completed the space-level analysis needed to support a production property election. - About 44% of leveraged companies carrying disallowed interest have not re-modeled their interest capacity under the restored EBITDA base. - Roughly two in three equipment structuring decisions are made before the company’s tax function is consulted. - Capture rates varied by industry. - Business aviation buyers captured an estimated 71% of available value. - Oil and gas operators captured 66%. - Private equity portfolio companies captured 60%. - Manufacturers captured 57%. - Data center operators captured 51%. - Marine operators captured 53%. - Mining operators captured 49%. - The report says the lowest capture rates show up in the most capital-intensive segments because those businesses generate depreciation faster than they generate taxable income to absorb it. - First National Capital Corp. says the five main sources of lost value are unusable deductions from losses or carryforwards, legacy tax elections under the 2022 to 2024 interest rules, equipment and aircraft bought under contracts signed before the January 2025 cutoff, facility projects built without required documentation, and financing timelines that push assets past year-end placed-in-service dates. - The report recommends mapping tax capacity before approving capital plans and evaluating financing on total value captured, not rate alone. - First National Capital Corp. says it has completed more than $4.5 billion in funding for equipment, technology, aircraft and capital projects across North America. - The company says its transaction capacity ranges from $500,000 to $250 million.

Between the lines: - The report argues the main problem is timing and structuring, not compliance. - In practical terms, tax benefits can disappear before a return is filed if the ownership entity, acquisition date, financing structure or placed-in-service timing is set without tax input. - The findings suggest companies with losses, delayed projects or more complex financing are least likely to capture the full OBBBA benefit. - The report also implies that capital providers and operating teams may need tighter coordination if they want to maximize after-tax return.

What’s next: - Companies with new capital plans will likely need to review tax capacity earlier in the approval process. - Businesses may also need to revisit entity ownership and financing structures before signing contracts or breaking ground. - The report’s core message is that the best financing decision may no longer be the lowest nominal rate, but the structure that captures the most tax value.

The bottom line: - First National Capital Corp. says the OBBBA offers meaningful capital investment relief, but most companies are not capturing the full value because they are making tax-sensitive decisions too late.