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Note 13 - Subsequent Events: Enactment of the One Big Beautiful Bill Act
6 Months Ended
Jun. 28, 2025
Notes to Financial Statements  
Subsequent Events [Text Block]

(13)        Subsequent Events: Enactment of the One Big Beautiful Bill Act

 

On July 4, 2025, the President signed into law the One Big Beautiful Bill Act (Public Law 119-21), which includes significant modifications to the Internal Revenue Code. The legislation permanently extends and modifies key provisions of the Tax Cuts and Jobs Act of 2017 and introduces new deductions and credits applicable to both individuals and businesses.

 

Key provisions relevant to the Company include:

 

Restoration of Immediate Expensing for Domestic Research and Experimental ("R&E") Expenditures: Effective for tax years beginning after December 31, 2024, domestic R&E expenditures may be immediately expensed under new Section 174A, reversing the prior capitalization and amortization requirement. This change may materially impact the Company’s deferred tax assets and current tax expense depending on the volume of qualifying expenditures.

 

It is anticipated that the unamortized Section 174 R&E expenditures at Q2 2025 will be expensed as follows (subject to further analyses and discussions):

 

   

2025

   

2026

   

Total

 

Rationale

Q3 2025

    899,728       -       899,728  

Expense remaining unamortized for 2025 and 37.5% of 2022-2024

Q4 2025

    187,193       -       187,193  

Expense 12.5% of 2022-2024

Q1 2026

    -       187,193       187,193  

Expense 12.5% of 2022-2024

Q2 2026

    -       187,193       187,193  

Expense 12.5% of 2022-2024

Q3 2026

    -       187,193       187,193  

Expense 12.5% of 2022-2024

Q4 2026

    -       187,193       187,193  

Expense 12.5% of 2022-2024

Totals

    1,086,921       748,772       1,835,693    

 

Enhancement of Section 179 Expensing: The maximum Section 179 deduction is increased to $2.5 million, with a phase-out threshold beginning at $4 million. This expansion is expected to accelerate tax deductions for qualifying property and benefit capital investment strategies.

 

Permanent Reinstatement of 100% Bonus Depreciation: For qualified property acquired and placed in service after January 19, 2025, the Company may elect full expensing under Section 168(k), which is expected to accelerate tax deductions and reduce taxable income in applicable periods.

 

Modifications to FDII (now FDDEI): The deduction under Section 250 for foreign-derived intangible income is reduced to 33.34%, and eligibility criteria are narrowed. These changes may impact export-related tax incentives and deferred tax projections tied to U.S.-held IP.

 

The Company is currently evaluating the impact of these provisions on its financial statements and tax positions. While the changes are not expected to materially affect prior period results, they may influence future effective tax rates, deferred tax balances, and cash tax obligations. The Company will incorporate these changes into its tax planning and provision calculations for fiscal year 2025 and beyond. However, the full effect of these provisions will depend on the Company's future capital expenditures, R&E activities, financing arrangements, and international operations. The Company will incorporate these changes into its tax provision and planning beginning in fiscal year 2025.