NYAIR Episode 108
The Investment Table: Lunchtime Webinar | OBBBA Unpacked: What Alternative Investment Professionals Need to Know
Daniel M. Reach, Partner at Alston & Bird, and Samit Shah, Principal in Grant Thornton’s Transfer Pricing Practice, discussed the OBBBA on the September 17 Webinar. Together, they drew on their expertise in tax, corporate finance, and international transactions to provide insights into the law’s implications for businesses and cross-border operations.
Featured Guests
Samit Shah
Principal, National Transfer Pricing Practice, Grant Thornton
Samit serves as a Principal of the Firm’s Transfer Pricing Practice based in the Atlanta, Georgia. Samit joined the Firm after 13+ years at EY and 3 years leading a national accounting firm’s transfer pricing practice. Over the past several years, Samit’s focus has been on the Life Sciences Industry as he served as lead on many supply chain reorganizations, IP migrations, APA and Controversy, financing transactions, tax reform planning, as well as global documentation.
Danny Reach
Tax Partner, Alston & Bird
Danny Reach is a partner in the tax group of Alston & Bird. He regularly structures and advises on mergers and acquisitions and fund formations and investments. He also advises clients on tax matters relevant to cross-border financings and restructurings, and he serves as underwriter’s counsel for insurers in the tax insurance space, covering highly complex tax matters.
Key Insights From This Episode
Interest Deductibility Returns to EBITDA
OBBBA reverts limitations to EBITDA from EBIT, boosting allowable interest deductions and aiding leveraged investment modeling, though transition rules require careful planning.
Domestic R&D Expensing Restored to 100%
Immediate full deductibility for U.S.-based R&D reverses TCJA amortization, enhancing cash flow for innovation-driven funds, while foreign R&D remains on 15-year schedules.
FDII Deduction Simplified for Manufacturers
The return-on-assets hurdle is eliminated, enabling lower ETRs for U.S. manufacturers exporting, aligning with reshoring goals and materially impacting fund portfolios.
QSBS Holding Period Shortened to 3 Years
Post-July 5, 2025 stock qualifies for partial exclusions after 3 years (50%), rising to 100% at 5 years; gain cap rises to $15M (inflation-adjusted) or 10x basis, with gross assets to $75M.
100% Bonus Depreciation for Production Property
Qualified production property placed in service before 2031 gets full expensing, spurring U.S. manufacturing and data center investments key to alternative strategies.
State Conformity Lags Federal Changes
States may not fully adopt OB3 provisions like bonus depreciation or R&D, creating planning complexities for multi-state funds and operations.
Access the Full Conversation
Dive into the complete audio for detailed transition rules, modeling examples, and Q&A on family offices, M&A elections, and depreciation recapture. Download the custom insights deck tailored for financial services pros—to supercharge your 2025-2026 tax strategies, ETR forecasts, and investment timing.
Soundbites Worth Saving
“From a modeling and planning perspective, it allows for more interest deduction. Overall, it also allows for some thinking about how to best do this given there are certain transition rules in place.”
— Samit Shah
“If you've invested $1.5 million or greater... your gain would be up to 10 times that basis. Really powerful benefit.”
— Danny Reach
Shape the Future of Alternatives With Us
The New York Alternative Investment Roundtable brings together the brightest minds in finance—Nobel laureates, industry disruptors, Fortune 1000 executives, and leading fund managers. By joining as a member, you gain access to premium events, exclusive insights from our podcasts, and direct connections with the decision-makers shaping global markets.
Your seat at the table is waiting.
GET IN TOUCH:
© 2025 New York Alternative Investment Roundtable | Privacy Policy | Terms and Conditions