Why this matters for trucking now
IRS guidance on the 2025 One Big Beautiful Bill Act (OBBBA) is arriving in pieces, and the timing matters for how fleets and owner-operators plan 2026–2027 equipment buys and facility projects. CFO Dive reports that tax pros expect a steady stream of clarifications this spring, especially around cost recovery, the new “qualified production property” bucket, and interplay with the corporate alternative minimum tax (CAMT). In some cases, OBBBA lets companies expense in one year what used to take decades—powerful cash-flow fuel for truck, trailer, and shop investments. But several definitions and elections still need fine-tuning, so watching for updates is essential.
100% bonus depreciation is back—and familiar
On January 14, 2026, Treasury and the IRS issued Notice 2026-11, confirming permanent 100% bonus depreciation under Section 168(k) for eligible property acquired after January 19, 2025 and generally placed in service after January 20, 2025. The notice tells taxpayers to largely rely on the existing bonus-depreciation regulations—a big help because the rules and elections (like timing, eligibility, and method) will look familiar to anyone who used bonus in prior years. For carriers, that means tractors, trailers, onboard tech, shop tools and many other tangible assets can often be written off immediately when properly placed in service.
- Key dates: The guidance updates the legacy “acquired/placed in service” cutoffs to January 19–20, 2025, aligning them with OBBBA.
- Component election: You may elect bonus on qualifying components of a larger self-constructed asset—even if the overall asset doesn’t qualify—useful for shop build-outs and yard improvements with discrete equipment packages.
- Elect 40% instead of 100%: OBBBA added an option to take 40% bonus (60% for certain long-production property/aircraft) for the first taxable year ending after January 19, 2025—handy if you want to smooth income rather than zero it out. The election is made on a timely filed return and, once made, can’t be revoked without IRS consent.
What it means on the ground: A $220,000 day-cab and a $70,000 dry van placed in service in 2026 could be fully expensed in year one under 168(k), subject to qualification and elections—freeing cash for fuel, payroll, and maintenance. Always model the impact on quarterly estimates and lender covenants before you elect.
New: first-year write-offs for certain buildings used in production
OBBBA created Section 168(n), a special depreciation allowance for “qualified production property” (QPP)—generally, nonresidential real property used as an integral part of a qualified production activity. On February 20, 2026, the IRS issued interim rules (Notice 2026-16) explaining definitions, computation, elections, and recapture if a property stops qualifying. While meant for manufacturing, chemical production, agriculture, or refining, tax pros note the definition of “production” can be broad—CFO Dive cites examples as simple as “mixing two chemicals.” For trucking, that could put certain tire-retread operations, parts remanufacturing, diesel blending, or dedicated upfitting facilities in the conversation. Documentation will be critical, and more guidance is expected.
Big-carrier caveat: CAMT interactions
Large fleets with average annual financial-statement income above $1 billion should watch CAMT. IRS issued additional interim direction in mid-February on OBBBA-related CAMT application, and further detail is likely. For smaller carriers and owner-operators, CAMT generally won’t bite, but it can affect partners, vendors, and shippers, which may influence payment terms or equipment programs.
Action checklist for Q1–Q2 2026
- Time deliveries and in-service dates: Coordinate OEM slots and dealer prep so qualifying tractors, trailers, APUs, shop gear, and IT hardware hit “placed in service” dates that lock in 100% expensing.
- Decide on your bonus strategy: Run tax models comparing 100% vs. the optional 40% election to manage taxable income, NOLs, and credit usage. Document elections on your timely filed return.
- Leverage the component election: For yard expansions or terminal upgrades, consider separating qualifying equipment components to capture immediate write-offs even if the larger project won’t fully qualify.
- Evaluate QPP potential: If you operate in-house retread, upfit, blending, or parts reman programs, explore whether your nonresidential real property could meet Section 168(n) criteria; set up substantiation now to support any election and guard against recapture.
- Track pending guidance: CFO Dive expects additional IRS interpretations on R&D expensing and other OBBBA wrinkles between April and early summer—assign a point person to monitor updates and update models.
Bottom line: OBBBA’s cost-recovery changes are a rare chance to turn 2026 capex into immediate tax savings. With several definitions and elections still being clarified, tight coordination among tax advisors, procurement, and operations will help you capture the benefit while avoiding unpleasant recapture or AMT surprises.
Sources Consulted: CFO Dive; IRS Newsroom and Internal Revenue Bulletin; PwC Tax Insights; BDO; Iowa State University Center for Agricultural Law & Taxation.
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This article was prepared exclusively for truckstopinsider.com. For professional tax advice, consult a qualified professional.
