
Section 461(l) Excess Business Loss Limitation: A 2026 Guide for Pass-Through Owners
Section 461(l) caps 2026 excess business losses at $128,000 single and $256,000 joint, per the OBBBA. Pass-through owners use Form 461 to report the limitation.
#bonus-depreciation
First-year bonus depreciation rules, qualifying property, and tax savings under the One Big Beautiful Bill Act

Section 461(l) caps 2026 excess business losses at $128,000 single and $256,000 joint, per the OBBBA. Pass-through owners use Form 461 to report the limitation.

OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.

Section 280F caps first-year depreciation on passenger autos at $20,300 in 2026, but SUVs and trucks rated above 6,000 lbs GVWR escape those limits and can combine a $32,000 Section 179 deduction with 100% bonus depreciation. A practical guide to the 2026 numbers, the heavy-vehicle and pickup carve-outs, the 50% business-use cliff, and the mileage-log standards an IRS auditor expects.

How short-term rentals sit outside the Section 469 passive loss rules, what the seven-day average and material participation tests actually require, and how a six-figure W-2 earner can use cost segregation and 100% bonus depreciation to legally offset wage income.

OBBBA made the 20% QBI deduction and 100% bonus depreciation permanent for 2026, while tariffs near 19% cost U.S. small businesses about $85 billion a year. Here is what changed, who benefits, and how to plan.

A cost segregation study reclassifies a building's components into shorter MACRS lives, unlocking the 100% bonus depreciation permanently restored by the One Big Beautiful Bill Act of July 2025. On a $1M residential rental, that swings first-year tax savings from roughly $10,700 to roughly $90,600—provided the investor clears IRC §469 passive activity loss limits.