The following questions address issues of great relevance to Italian companies in relation to U.S. tax law, with particular reference to Section 179 and possible legislative changes, such as the so-called "Big Beautiful Act" (an informal name, political rather than technical in nature). Below we provide detailed, point-by-point answers:

1. Section 179: is it really beneficial?

Yes, Section 179 of the Internal Revenue Code (IRC) has for years been one of the most favorable tools for companies acquiring capital assets, including machinery, plant, equipment and software. The legislation allows an immediate deduction (rather than multi-year depreciation) of the cost of depreciable assets, up to a specified annual limit.

For tax year 2025, barring any changes, the deduction limit is expected to be around $1.22 million, with a maximum total investment threshold (beyond which the deduction begins to reduce) of about $3 million.

This measure is also widely used by companies that import capital goods from abroad, as long as the goods are tangible, new or used (unrelated party) and intended to be used in the United States for business purposes.

2.Is the measure already operational?

Section 179 is already operational and permanent.

As for the so-called "Big Beautiful Act," it does not currently appear to have been passed as federal law. There may be legislative proposals or policy statements to expand tax benefits for manufacturing, but no new legislation with that designation has been introduced at this time.

3. Do assets have to be installed by Dec. 31, 2025?

Yes, the basic rule to take advantage of the Section 179 deduction is that the assets must be purchased and "placed in service" by the end of the tax year. This means that the equipment must be delivered, installed and operational (not just purchased or ordered) by December 31 of the year in which the deduction is claimed.

Therefore, to qualify for the deduction in 2025, the assets must be put into service by December 31, 2025.

4. Does the United States grant extensions?

In general, the annual deadlines related to Section 179 are fixed and are not extended each year, except by specific Congressional action, which could pass changes, such as:

* the raising of deduction limits;
* the extension of "bonus depreciation" (a complementary measure to Section 179).

However, there is no certainty that these deadlines will be extended. If a company plans to make a strategic purchase, it is advisable to meet the deadline of December 31, 2025, unless new provisions are approved.

In summary, the answers to the above questions are as follows:

Finally, the legislation is particularly beneficial, especially if the company intends to install machinery by Dec. 31, 2025 in the United States. If the investment falls within the deductible limits, an immediate deduction of up to $2.5 million is available, as well as the possibility of taking advantage of "bonus depreciation" of up to 100 percent. It is, however, essential to meet the December 31, 2025 deadline or monitor any future extensions or legislative changes.

For further consideration, we recommend that you consult your accountants and/or lawyers, as we are a commercial office of the Italian government and our staff is not authorized to provide legal or tax advice.