Tax Incentive Programs

The recently passed "One Big Beautiful Bill" (OBBB) introduces substantial tax benefits, creating valuable opportunities for family offices and real estate investors focused on preserving and growing wealth. Understanding and acting on these changes can significantly improve your investment strategy and offer lasting financial advantages: • Permanent 20% QBI Deduction: Provides long-term tax savings for pass-through entities, increasing profitability and investment potential. • Permanent 100% Bonus Depreciation: Enables immediate deductions on property improvements and tangible assets, significantly improving cash flow. • Increased Estate and Gift Tax Exemption: Exemption limits have increased to $15 million per individual ($30 million per couple), simplifying the transfer of generational wealth. • Expanded SALT Deduction: The limit for State and Local Tax (SALT) deductions, including property and income taxes, rises from $10,000 to $40,000 starting in 2025. Full benefits apply only to individuals with modified adjusted gross income (MAGI) below $500,000 (or $600,000 for joint filers). Above those levels, the deduction gradually phases out, ultimately reverting to $10,000 once income reaches approximately $600,000. • Enhanced Affordable Housing Incentives: A 12% increase in Low Income Housing Tax Credits makes affordable housing investments more financially attractive. Investors can achieve stronger yields while contributing to community development and meeting ESG objectives. These provisions offer more than incremental tax savings. They create strategic financial opportunities for real estate investment and wealth transfer planning. Are you prepared to take full advantage of these new tax opportunities? Now is an ideal time to review your investment and estate strategies. Taking action today can secure financial benefits for years to come.

🎬 FILM FINANCING 101: Tax Incentives – "Hitting the Bullseye" - Free Money That’s Anything But Simple Tax incentives are one of the most powerful tools in film financing - often covering 20–40% or more of a production’s qualified spend. They can reduce your equity ask, improve investor ROI, and unlock otherwise unreachable budgets. But incentives are also complex, vary by location, and come with critical strings attached. Here’s what producers need to understand: ✅ Credits, Rebates & Grants – Know the Difference - Transferable tax credits (e.g. Georgia, Illinois): These can be sold to third parties for upfront cash. - Refundable credits (e.g. Canada, New Mexico): The government sends you a check after audit (tied to taxes). - Cash grants (e.g. Texas, select EU regions): Paid out by a government fund after compliance review (not tied to taxes). ➡️ All of these can be cash-flowed during production using gap lenders - but only if your paperwork, timing, and state approvals are in order. ✅ Location Matters – But So Does Infrastructure States and countries with aggressive incentives often lack the crew depth, gear houses, or post infrastructure to support a full-scale production. 🔥 A 35% rebate sounds great - until you’re importing half your team, blowing the travel budget, or losing time to local inexperience. Savvy producers do the math: the rebate must beat the additional logistical cost, or you’re upside down. ✅ Texas as a Case Study (Starting Sept 2025) New program under SB 22 includes: – 5–25% base cash grant depending on spend level – Up to +6% in bonuses for veteran hires, rural regions, in-state post, and more – Total possible return: ~31% ⚠️ However, it requires TX-based crews, limits adult content, and only pays after production - like most U.S. programs. ✅ International Can Go Bigger - But With Hurdles Countries like Portugal, Hungary, Canada, and Colombia offer 25–50% back, but often require: – Co-production partners – Local spending minimums – Cultural content qualifications – Extended payment timelines and audits Currency risk, legal costs, and repatriation issues must be factored in. 💡 Bottom Line Tax incentives are real money - but not free money. They require smart budgeting, early planning, legal strategy, and local execution. Know the rules. Plan the structure. And don’t chase rebates into a production trap. Next up: Pre-Sales – When Territory Buyers Bet on Your Cast, Not Your Script Note: Every deal is different and incentives constantly change, do your research! #FilmFinance #TaxIncentives #Producing #FilmBudgeting #EntertainmentBusiness #IndependentFilm #CreativeProducing #DesertPirateProductions #GapFinancing #FilmInvestors

The Cyprus Parliamentary Committee on Financial and Budgetary Affairs has highlighted the urgent need for compensatory measures to safeguard Cyprus’s competitiveness and prevent MNEs from relocating. This comes in response to the EU Directive implementing a 15% global minimum effective tax rate under Pillar Two. The concern is that popular tax incentives, such as the IP Box and NID regimes, may lose their appeal under these new rules. A potential roadmap for adapting to this challenge can be found in the 2022 OECD report, "Tax Incentives and the Global Minimum Corporate Tax: Reconsidering Tax Incentives after the GloBE Rules." The report suggests practical solutions that Cyprus and other jurisdictions can consider to align tax policy with the evolving global framework: Key Takeaways from the OECD Report: 👉 Deferred Tax Payment Incentives Tax incentives that defer tax payments into the future, such as immediate expensing (100% first-year allowance) or accelerated depreciation of tangible and short-lived intangible assets, are generally less likely to trigger top-up taxes under the GloBE rules. 👉 Qualified Refundable Tax Credits These are more resilient under Pillar Two compared to nonrefundable credits. For instance, Ireland’s recent increase in its R&D tax credit (from 25% to 30%) aligns with the Pillar Two definition of "qualified refundable tax credits" and demonstrates how incentives can be adapted for compliance. Ideas for converting existing incentives into new incentives: 👉 IP Box Regime Adjustments To preserve the benefits of the Cyprus IP Box regime, further amendments may be necessary to ensure it meets the “qualified refundable tax credit” definition. Such changes would help sustain its viability as an effective incentive under the new rules. 👉 Ideally, such expenditure-based incentives (e.g. immediate expensing and accelerated depreciation) should be in line with the Pillar 2 carve-out, namely SBIE which reflects the scale of economic substance, i.e. payroll and tangible assets. In this way, such tax incentives that are linked to the size of economic substance would be more resistant to the Pillar 2 Rules. Cyprus must take proactive steps to modernize its tax incentives to remain attractive while adhering to global standards. Collaboration among policymakers, businesses, and tax professionals is crucial to ensure the IP Box regime and other incentives continue to drive investment and innovation in a compliant manner. What other measures or strategies could Cyprus explore to stay competitive under the new tax regime? Let’s discuss! The OECD report can be found at the link below https://lnkd.in/dDYp6r-g

I was recently asked about the comment period on the 45V tax credit in the IRA and what should be suggested to Treasury to make projects more desirable. The incentive is a production tax credit (PTC) of up to $3/kg of green hydrogen. The PTC is designed to jumpstart green hydrogen production and make it more attractive compared to gray or blue hydrogen. The recently proposed rules will limit the impact of the incentive. If Treasury can accept some short-term adverse effects, i.e. natural gas-produced electricity, and issue more favorable requirements, the PTC will have a greater effect and accelerate the growth of the green hydrogen industry. Treasury also should include excess hydroelectric and nuclear power, the two most abundant energy sources that do not create CO2, as part of the program. During a LinkedIn webinar on the subject earlier this month, one of the panelists compared the regulations to flying an airplane. When an airplane takes off, it has specific settings for speed, flaps, etc. Once the airplane reaches cruising altitude, the settings are different. The same can be true with the 45V guidelines. The requirements should be more lenient in the beginning and adjust as the industry becomes established. Given the length of time it takes to build renewable sources and hydrogen plants, the gestation period for the hydrogen economy to mature will be lengthy. To expedite the development of the industry, Treasury should make adjustments to the current guidelines. Some, such as deliverability, could be phased in early.  However, the more stringent guidelines, like additionality and hourly temporal matching, should be phased in gradually, perhaps over a ten-year period, which just happens to be the duration of the 45V tax credit.  https://lnkd.in/eMMc7kfV

📝 𝗔𝗻 𝗼𝘃𝗲𝗿𝘃𝗶𝗲𝘄 𝗼𝗳 𝘁𝗮𝘅 𝗶𝗻𝗰𝗲𝗻𝘁𝗶𝘃𝗲𝘀 𝗳𝗼𝗿 𝗳𝗼𝗿𝗲𝗶𝗴𝗻 𝘄𝗼𝗿𝗸𝗲𝗿𝘀 𝗮𝗰𝗿𝗼𝘀𝘀 𝗘𝘂𝗿𝗼𝗽𝗲 Two weeks ago, I posted about Germany’s plan to introduce a tax rebate for foreigners to attract more skilled workers. Many countries in Europe have been doing this for a long time. And at WorkMotion, we are helping thousands of talents access these benefits through their payroll on a daily basis. I couldn’t find a good overview of the most relevant tax benefits across countries, so I created it myself 🌍💼 🇵🇹 𝗣𝗼𝗿𝘁𝘂𝗴𝗮𝗹 - 𝗡𝗼𝗻-𝗛𝗮𝗯𝗶𝘁𝘂𝗮𝗹 𝗥𝗲𝘀𝗶𝗱𝗲𝗻𝘁 (𝗡𝗛𝗥) 𝗥𝗲𝗴𝗶𝗺𝗲 Introduced: 2009 Eligible: Non-Portuguese nationals living and working in Portugal for more than 6 months per year Tax benefit: 20% flat tax rate instead of regular rate which goes up to 48% Duration: Up to 10 years 🇪🇸 𝗦𝗽𝗮𝗶𝗻 - 𝗕𝗲𝗰𝗸𝗵𝗮𝗺 𝗟𝗮𝘄 Introduced: 2005 Eligible: Individuals who have not been tax residents in Spain for the past 10 years Tax benefit: 24% flat tax rate vs. regular tax rates that go up to 47% Duration: Up to 6 years 🇮🇹 𝗜𝘁𝗮𝗹𝘆 - 𝗜𝗺𝗽𝗮𝘁𝗿𝗶𝗮𝘁𝗲 𝗥𝗲𝗴𝗶𝗺𝗲 Introduced: 2016 Eligible: Workers and professionals moving to Italy who have not been Italian tax residents in the last 2 years Tax benefit: 70% tax exemption on income, with an increase to 90% in Southern Italy: That’s why one of my former team members moved from Germany to Sicily. It works! Duration: 5 years, extendable to 10 years 🇳🇱 𝗡𝗲𝘁𝗵𝗲𝗿𝗹𝗮𝗻𝗱𝘀 - 𝟯𝟬% 𝗥𝘂𝗹𝗶𝗻𝗴 Introduced: 1960s and reformed in 2012 (the Dutch were pioneers here) Eligible: Highly skilled workers recruited from abroad Tax benefit: Tax-free reimbursement of up to 30% of gross salary Duration: Up to 5 years 🇩🇰 𝗗𝗲𝗻𝗺𝗮𝗿𝗸 - 𝗘𝘅𝗽𝗮𝘁𝗿𝗶𝗮𝘁𝗲 𝗧𝗮𝘅 𝗦𝗰𝗵𝗲𝗺𝗲 Introduced: 1992 Eligible: Highly paid employees recruited from abroad, earning above DKK 77.5k p.m. (~€10k p.m.) Tax benefit: 27% flat tax rate on income instead of the regular top rate of 55.8% Duration: 5 years at the flat rate, followed by 2 years at regular rates 🇸🇪 𝗦𝘄𝗲𝗱𝗲𝗻 - 𝗘𝘅𝗽𝗲𝗿𝘁 𝗧𝗮𝘅𝗮𝘁𝗶𝗼𝗻 𝗥𝗲𝗹𝗶𝗲𝗳 Introduced: 2001 Eligible: Foreign experts, researchers, and key executives working in Sweden Tax benefit: 25% of gross income is tax-free for the first 3 years, reducing the effective tax rate from the regular rate which can be up to 52% Duration: 3 years 🇲🇹 𝗠𝗮𝗹𝘁𝗮 - 𝗛𝗶𝗴𝗵𝗹𝘆 𝗤𝘂𝗮𝗹𝗶𝗳𝗶𝗲𝗱 𝗣𝗲𝗿𝘀𝗼𝗻𝘀 (𝗛𝗤𝗣) 𝗦𝗰𝗵𝗲𝗺𝗲 Introduced: 2011 Eligible: Professionals in specific industries, e.g. financial services, tech, aviation, etc. Tax benefit: 15% flat tax rate on employment income instead of regular rates up to 35% Duration: Up to 5 years, with possible extension --- And soon maybe: 🇩🇪 𝗚𝗲𝗿𝗺𝗮𝗻𝘆 - ? Introduced: ? Eligible: Newly immigrated skilled workers Tax benefit: 30%, 20%, 10% of income would be tax-free in first 3 years respectively Duration: 3 years #RemoteWork #LabourShortage #Tax #Expats #Finance #Hiring

Saudi Arabia is offering tax incentives to foreign companies that establish their regional headquarters in the country, including a 30-year exemption from corporate income tax. These incentives, implemented by the Ministry of Investment and the Royal Commission for Riyadh City, aim to attract international firms to open regional headquarters in the Middle East and North Africa region in Saudi Arabia. Key opportunities for international large corporates include: Tax Exemptions: The 30-year corporate income tax exemption and zero income tax for foreign entities relocating their regional headquarters offer substantial cost savings. Saudization Benefits: Firms complying with Saudization requirements can access special benefits, encouraging the employment of Saudi nationals. Business Environment: Saudi Arabia's favorable business environment has already attracted over 200 companies to relocate their headquarters, showcasing the country's attractiveness for international firms. Vision and Stability: The tax exemptions provide clarity and stability to firms, enhancing their capabilities for long-term planning and regional expansion, starting from Saudi Arabia. Growing Ecosystem: Saudi Arabia is actively collaborating with international entities to create a conducive ecosystem for opening offices in the country, offering potential partners a supportive environment. Stability: Amidst geopolitical tensions and economic challenges, Saudi Arabia presents itself as a stable and secure destination for international investors. Notable companies like PwC Middle East and GE Healthcare have already established their regional headquarters in Saudi Arabia, indicating the growing interest and opportunities for international corporates in the Kingdom. #saudiarabia #vision2030 #RHQ #business #investment #industry

Why overpay taxes when the government’s practically paying you to invest? If you have a 401(k) or a mortgage, you’re already getting tax breaks that most folks miss. But in commercial real estate, Uncle Sam really rolls out the red carpet—especially if you’re tackling green projects, adding affordable housing, or simply tired of huge tax bills. Case in Point I recently helped develop a 239-unit community in San Antonio. We came in $750k under budget, secured a 42-year HUD loan at 4.38%, and projected a healthy 16.6% IRR over 10 years before layering on these tax incentives: Opportunity Zones – Eliminate capital gains tax after a 10-year hold. 45L Credits – More than $550k in direct offsets for energy-efficient units. Cost Segregation + Bonus Depreciation – Paper losses to offset other income, with no recapture in an OZ. PFC Structure – By making 50% of units affordable, we avoid property taxes for 75 years. The Catch? It’s not easy—there’s red tape, and you have to know how these programs work together. But if you align all the pieces, your returns can make the IRS feel like a silent partner (in a good way). Question: Are you still overpaying taxes, or are you making the tax code work for you? Share your strategies in the comments—and let’s keep more of what we earn. #OpportunityZones #RealEstateInvesting

🔍 Rethinking Your Renewable Strategy? Here’s What the Numbers Say About Tax Credits and since there is so much discussion on this currently. As investors and corporate leaders revisit clean energy strategies in the U.S., a key question looms: Can renewable energy survive without tax credits? Yes—but not quite yet in opinion.. 📊 The economics are strong: The cost of utility-scale solar has dropped by 90% since 2009, and wind by nearly 70%. In 2023, solar and wind made up over 60% of new power capacity additions in the U.S. Lazard’s 2024 LCOE report shows unsubsidized wind and solar cost between $24–$60/MWh, competitive with natural gas ($39–$101/MWh). ⚠️ But tax credits still matter—for now: The Investment Tax Credit (ITC) and Production Tax Credit (PTC) cut project costs by 20–30%, enabling faster payback and reducing risk. The U.S. tax equity market—vital for clean energy financing—was worth $18 billion in 2023, with the majority tied to tax incentives. Fossil fuels still benefit from over $20 billion annually in direct and indirect U.S. subsidies, making the playing field uneven. 💰 Opportunity window: The Inflation Reduction Act (IRA) extended tax credits through at least 2032, including bonus credits for domestic content, energy communities, and workforce development. It’s expected to drive $1.7 trillion in private clean energy investment over the next decade. 🧭 What this means for you: Tax credits are not crutches—they’re strategic catalysts. Now is the time to capitalize on federal support, but also structure investments that remain resilient after incentives phase out. Delaying action risks missing out on multiplier effects—economic, reputational, and regulatory. If you’re reevaluating your renewable roadmap, build a bridge between policy and profitability—because the future of energy isn’t just green, it’s strategic. We need energy and more of it! #RenewableEnergy #CleanEnergyInvesting #InflationReductionAct #EnergyTransition #CorporateStrategy #TaxCredits #SustainableBusiness #ESG #GreenFinance

I’ve recently come across some well-designed state-level programs that use tax abatements to encourage affordable housing. The concept itself isn’t new, but what stands out is how these programs let developers opt in at a level that makes sense for their project’s underwriting—receiving a tax abatement directly proportional to the percentage of affordable units they provide. Here’s how it works: If a developer rents 30% of a property’s units at 80% of Area Median Income (AMI) levels, they receive a 30% tax abatement. Rent 50% of units at 80% AMI, and the abatement increases to 50%. This structure allows developers to balance affordability with financial feasibility, rather than forcing an all-or-nothing approach. But additionality is key—if an operator was already leasing those units at 80% AMI, the tax break isn’t actually creating new affordability. And in my experience underwriting these deals, once the income restrictions drop to a lower level (e.g. 50-60% AMI), the rents are often too low for the project to make sense, even with the abatement—though this varies by market. Another smart design choice? Keeping the reporting requirements simple. If operators only need to verify that units are leased at 80% AMI rent levels—without extensive tenant income certification—it removes a major barrier to participation. Programs like these can be a win-win, but the details matter. When structured well, they create real, additional affordable housing—not just a tax break.

Withholding Tax Credit Introduced for Qualified Foreign Investors Reinvesting Dividends in China China has introduced a new withholding tax credit to incentivize foreign investors to reinvest dividends in the country. This program could improve after-tax returns on reinvested profits for foreign MNCs, but only if the right conditions are met. Our latest alert unpacks the rules, qualifying structures, and the considerations. #ChinaTax #WithholdingTax #FDI #DividendReinvestment #InternationalTax #CrossBorderInvestment #TaxPlanning #ForeignInvestmentChina