First National Capital, a large independent provider of capital equipment and project financing in North America, released The Unclaimed Dividend, a cross-sector research report examining how mid-sized and large companies are using the capital investment provisions of the One Big Beautiful Bill Act (OBBBA). The research finds that companies captured an estimated 61% of the value these provisions made available on 2025 capital spending, measured as the present value of federal tax savings the OBBBA adds over prior cost recovery rules at a 21% rate and 8% discount rate. Among firms with $20 million or more in annual CapEx, where median spending is about $42 million, that leaves a median of roughly $740,000 a year unclaimed.
The report focuses on the three OBBBA provisions with the greatest impact on capital-intensive businesses: permanent 100% bonus depreciation; the new 100% expensing election for qualified production property; and the restoration of EBITDA as the base for the business interest limitation under Section 163(j).
Among the key findings: fewer than one in five manufacturers with qualifying construction underway have completed the space-level analysis needed to support a production property election. Some 44% of leveraged companies carrying disallowed interest have not re-modeled their interest capacity under the restored EBITDA base. And roughly two in three equipment structuring decisions are made before the company’s tax function is consulted.
Capture rates varied sharply by industry. Business aviation buyers captured an estimated 71% of available value, while oil and gas operators captured 66%, private equity portfolio companies 60%, and manufacturers 57%. The most capital-intensive segments trailed: data center operators at 51%, marine operators at 53%, and mining operators at 49%, largely because they generate depreciation faster than they generate taxable income to absorb it.
The research identifies five recurring sources of lost value: deductions companies cannot use because of losses or carryforwards; legacy tax elections made under the 2022 to 2024 interest rules that now block bonus depreciation and facility expensing; equipment and aircraft acquired under contracts signed before the January 2025 cutoff; facility projects built without the documentation production property expensing requires; and financing timelines that push equipment past year-end placed-in-service dates. The report recommends companies map tax capacity before approving capital plans and evaluate financing on total value captured, not rate alone.
“The benefits are being claimed in form and forfeited in substance,” Finbar O’Donoghue, chief revenue officer of First National Capital, said. “Nobody is filing these returns incorrectly. The value is lost months earlier, when the acquisition date, the ownership entity, the financing structure and the in-service timing get locked in by people who were never asked to think about tax. Under a law change this generous, the true cost of capital is no longer the rate. It is the rate minus the tax value you actually capture.”
O’Donoghue added, “An important question in a financing decision today is which party can use each asset’s depreciation right now. For a profitable company, that is usually the company itself. For a data center in build-out, a miner coming out of a cycle, or a portfolio company carrying losses, it often is not. The companies capturing full value match ownership of every asset to the party best positioned to use it, and they line up capital early enough to hit the calendar.”
The Unclaimed Dividend draws on research conducted through Secured Research, including inferred survey data and sentiment analysis from 612 finance decision-makers at companies with annual revenue of $50 million to more than $2 billion, fielded from July through September 2026, supplemented by FNCC proprietary transaction data. The full report is available at https://firstncc.com/the-unclaimed-dividend/.
