Summary and Rewrite: On July 4, 2025, the One Big, Beautiful Bill Act (“Act”) was enacted, bringing significant amendments to the Internal Revenue Code (“Code”) that affect both US and non-US companies engaged in domestic and international transactions, capital investment, research, and development, with considerable implications for the cryptocurrency and digital asset sector. The Act impacts numerous industry participants, including cryptocurrency exchanges, payment processors, asset managers, funds, mining entities, token issuers, custodians, and lending platforms—both centralized and decentralized—reshaping the tax environment and requiring careful attention. Key Provisions: 1. Research and Experimental Expenditures The Act reinstates full immediate expensing for domestic research and experimental (R&E) expenses under new section 174A, allowing taxpayers to deduct certain unamortized amounts from previous years. This offers prompt tax benefits to digital asset firms innovating in blockchain and protocol development within the U. S. However, foreign R&E remains amortized over 15 years. Companies should model effects carefully, considering implications such as the Corporate Alternative Minimum Tax. At the state level, conformity varies; some may permit immediate expensing while others might continue amortization, potentially causing timing mismatches and constitutional concerns regarding favorable treatment of domestic versus foreign R&E. 2. Bonus Depreciation and Immediate Expensing The Act permanently reinstates 100% bonus depreciation, benefiting mining companies by allowing immediate expensing of mining server and data center costs, and likewise aiding exchanges investing in server farms or security infrastructure. However, many states do not conform to federal bonus depreciation, requiring add-backs and longer depreciation schedules, thus causing timing differences and complexity for multi-state digital asset companies. 3. Business Interest Expense Deductions The Act reintroduces an EBITDA-based limitation on business interest expense deductions under section 163(j), easing the tax burden on companies dependent on debt financing, such as lenders, exchanges, miners, or corporations undergoing capital investments or mergers and acquisitions. However, exclusion of some foreign income from adjusted taxable income (ATI) could disadvantage certain entities. State-level impacts depend on conformity, with some states potentially decoupling, necessitating careful tracking of interest deductions across jurisdictions. 4. Revisions to Global Intangible Low-Taxed Income (GILTI) and Foreign Derived Intangible Income (FDII) Changes to GILTI and FDII—originally established by the Tax Cuts and Jobs Act—affect US-owned foreign entities and incentivize domestic sales and services. Digital asset companies with offshore operations or foreign customers should analyze these provisions’ effects.

State conformity varies, prompting a need to monitor local legislative responses to avoid adverse tax consequences. 5. State and Local Tax (SALT) Deduction The Act temporarily raises the SALT deduction cap for individuals to $40, 000 with income-based phase-downs, offering relief to high-income cryptocurrency founders and investors in states with elevated taxes. Notably, the pass-through entity tax workaround remains unchanged, allowing start-ups structured as LLCs or partnerships to continue shifting state tax burdens to reduce federal taxes. 6. Other General Changes A new excise tax is introduced on certain remittance transfers under the Electronic Fund Transfer Act definitions, potentially impacting digital asset firms involved in cross-border payments. The tax, however, applies only to transfers involving cash, money orders, cashier’s checks, or similar physical instruments, generally excluding cryptocurrency transactions unless the Treasury interprets broadly. Additionally, income tax exclusions for tips and overtime pay—aimed at supporting service and hourly workers—may influence digital asset companies employing contractors or gig workers, necessitating adjustments in payroll and tax reporting. Looking Forward: GENIUS, CLARITY, and Lummis Bills The Act emerges amid increased legislative efforts to define digital asset regulation comprehensively. The week of July 14, 2025, was declared “Crypto Week” by the U. S. House, featuring consideration of landmark bills such as the Digital Asset Market Clarity Act of 2025 (CLARITY) and the Senate’s Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS). These bills seek to establish clear regulatory frameworks, enhance financial privacy, and assert the U. S. as a leader in Web3 innovation. The GENIUS Act has passed both chambers and awaits the President’s signature, representing the most comprehensive regulation of payment stablecoins to date. The CLARITY Act passed the House and is under Senate consideration, aiming to clarify definitions and regulate when tokens cease to be securities. Senator Cynthia Lummis (R-WY) has also introduced legislation to overhaul digital asset taxation comprehensively. Ongoing monitoring of these developments is essential. In summary, the One Big, Beautiful Bill Act significantly modifies tax provisions impacting digital asset companies across research, capital investment, interest deductions, international income regimes, and state tax interactions, set against the backdrop of a broader legislative push to define and regulate the cryptocurrency landscape in the United States.