The “One Big, Beautiful Bill” (OB3)—commonly referred to as the Trump Tax Act—is reshaping the landscape for commercial real estate
During a recent CARW policy briefing, Reinhart Law experts Joe Shumow and Joe Rekrut unpacked the bill’s key provisions and their implications for developers, investors, and property owners.
Key Highlights from the Presentation:
Low-Income Housing Tax Credits (LIHTC)
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States will receive a 12% increase in funding for the competitive 9% credit—potentially delivering 1.2 million new housing units over 10 years.
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The 4% (non-competitive) credit bond-financing threshold drops from 50% to 25%, opening opportunities for more projects to qualify.
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Developers should weigh tradeoffs between taxable and tax-exempt bond financing as these rules shift.
Energy & Sustainability Incentives
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The 45L Energy-Efficient Homes Credit and 179D deduction must be claimed on properties placed in service by mid-2026.
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Solar and wind credits must begin construction by January 2026 and be in service by end of 2027—creating a near-term rush for eligible projects.
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Homeowners and developers are urged to complete projects early to secure benefits.
Tax Credits & Business Provisions
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Bonus depreciation is now permanent at 100% (for property acquired after Jan. 19, 2025) — but Wisconsin remains non-conforming.
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Section 179 expensing limits have doubled, and Section 199A deductions for pass-through entities are now permanent.
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Qualified Production Property (QPP) expensing applies to manufacturing and industrial facilities through 2031.
Opportunity Zones & New Markets
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New Markets Tax Credit made permanent at $5 billion annually; however, federal staffing shortages are delaying program administration.
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Opportunity Zones gain a rolling five-year holding period and stricter focus on low-income and rural tracts with enhanced data tracking.
Implementation Notes
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Federal agency delays are slowing IRS and Treasury guidance on several OB3 provisions.
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The Wisconsin Department of Revenue continues reviewing potential conformity changes but is unlikely to act soon.
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Presenters advised members to track energy-related deadlines and consult advisors early to maximize benefits.
“OB3 represents one of the most sweeping tax changes for real estate in a decade. Staying informed and proactive will be essential for anyone navigating new investments or development planning.”
— Joe Rekrut, Reinhart Boerner Van Deuren
Contact the Presenters:
Joe Shumow Shareholder & Chair, Real Estate Department 📧 jshumow@reinhartlaw.com | ☎ (414) 298-1000
Joe Rekrut Shareholder, Tax Department 📧 jrekrut@reinhartlaw.com | ☎ (414) 298-1000
Learn more at: www.reinhartlaw.com/contact