West Palm Beach, FL – October 20, 2025 — Engineered Tax Services (ETS), the nation’s leading specialty tax engineering firm, today expressed strong support for The Real Estate Roundtable’s letter to Treasury Assistant Secretary for Tax Policy, Kenneth Kies, requesting critical guidance to allow taxpayers to modify prior Real Property Trade or Business (RPTOB) elections under section 163(j)(7)(B) of the Internal Revenue Code.
The requested guidance would ensure that real estate owners and investors can fully benefit from the 100% bonus depreciation provision in the One Big Beautiful Bill Act (OBBBA) — a cornerstone of the legislation designed to spur economic growth, investment, and job creation across the country.
“This is a pivotal moment for America’s real estate and investment community,” said Julio Gonzalez, CEO and Founder of Engineered Tax Services. “The One Big Beautiful Bill Act restores 100% bonus depreciation and redefines business interest deductions in ways that will accelerate revitalization projects, stimulate local economies, and expand access to capital for property owners and small businesses. We applaud The Real Estate Roundtable’s leadership in advocating for this clarification from Treasury.”
Key Background
Under prior law established by the Tax Cuts and Jobs Act of 2017 (TCJA), the section 163(j) limitation on business interest deductions led many real estate owners to make RPTOB elections, which exempted them from the interest limitation but required the use of a slower depreciation schedule that disqualified them from immediate expensing.
The One Big Beautiful Bill Act (OBBBA) fundamentally reforms these provisions in two major ways:
1. Restores full (100%) bonus depreciation for qualifying capital expenditures and property improvements.
2. Expands business interest deductibility by changing how the 163(j) cap is calculated — redefining “adjusted taxable income” to include earnings before interest, tax, depreciation, and amortization (EBITDA), rather than after depreciation and amortization.
Together, these changes significantly reduce the need for many real estate owners to maintain RPTOB elections made under the prior regime. However, without new Treasury guidance, those who previously made RPTOB elections remain locked into less favorable depreciation treatment, limiting their ability to take advantage of OBBBA’s expanded incentives.
The Roundtable’s Request
The Real Estate Roundtable’s letter — signed by Jeffrey DeBoer, President & CEO — urges Treasury and the IRS to issue implementing guidance that allows taxpayers to withdraw prior RPTOB elections on a going-forward basis, consistent with OBBBA’s effective date. Similar relief was granted under the CARES Act of 2020, which modified section 163(j) and permitted taxpayers to retroactively amend elections.
“Without this clarification, property owners could be unfairly penalized for decisions made under outdated tax laws,” said Gonzalez. “Allowing RPTOB election reversals ensures fairness and supports the Act’s intent — to encourage modernization, investment, and job creation in every community.”
About Engineered Tax Services (ETS)
Engineered Tax Services (ETS) is the nation’s largest specialty tax and engineering firm, helping businesses, property owners, and municipalities unlock the full value of the U.S. tax code through cost segregation, 179D/45L energy incentives, R&D tax credits, and grant funding. ETS is dedicated to advancing tax equality by ensuring that small businesses and communities have access to the same tax benefits as large corporations.
For more information about how ETS supports real estate investors and business owners through the One Big Beautiful Bill Act, visit https://engineeredtaxservices.com/whats-in-the-one-big-beautiful-bill-and-what-it-means-for-you/
Media Contact:
Heidi Henderson
Executive Vice President
Engineered Tax Services
📞 (800) 236-6519
