Foreign direct investment (FDI) has long fueled U.S. economic growth, especially in manufacturing and distribution. By the end of 2024, inbound FDI reached $5.71 trillion, with strong contributions from electronics, transportation equipment, and clean energy. Georgia, in particular, has emerged as one of the nation’s key destinations, drawing $2.09 billion in FDI in 2023, while its exports surpassed $53 billion in 2024, underscoring its role as a hub for international trade and investment.
At the same time, global investment flows have grown more volatile, falling 11% in 2024 amid geopolitical uncertainty and shifting supply chains. Against this backdrop, Georgia’s business-friendly climate, low taxes, and generous state and local incentives give it a clear advantage in attracting international capital. Now, the One Big Beautiful Bill Act (OBBBA) amplifies those advantages, introducing federal-level incentives that align perfectly with Georgia’s strengths.
For inbound investors, OBBBA may seem complex at first glance. But several provisions stand out as especially powerful for manufacturing, clean energy, and distribution projects. Below is a guide to the opportunities most relevant for international companies considering Georgia.
100% Bonus Depreciation for U.S. Facilities
One of the most significant provisions of OBBBA is the restoration of 100% bonus depreciation for qualified property placed in service after January 19, 2025. This covers not only tangible equipment but also introduces a new category of “Qualified Production Property” (QPP), which includes nonresidential manufacturing real estate.
For foreign-owned projects in Georgia, this means that the full cost of construction and equipment can be deducted in the first year rather than spread out over decades. The ability to accelerate cost recovery provides a meaningful boost to early cash flow and improves the financial profile of new investments. To put it in perspective, a $50 million facility could yield more than $10 million in immediate federal tax savings at the standard 21% corporate rate. This is a powerful incentive for companies weighing the cost of U.S. expansion.
Expanded Tax Credits for Hydrogen and Clean Energy
OBBBA also expands federal support for clean energy projects, further enhancing Georgia’s appeal as a hub for renewable development. The legislation extends the Section 45V Hydrogen Production Credit to cover projects that begin construction through January 1, 2028, while also offering investment tax credits of up to 30% for hydrogen storage and fuel cell infrastructure such as tanks, pipelines, and compression systems.
What makes these credits especially attractive is their transferability. Companies can choose to sell or monetize them, creating a source of liquidity that can offset initial costs or be reinvested in other areas of the project. For international clean energy firms, this flexibility reduces risk, improves return on investment, and makes it easier to commit to large-scale facilities in Georgia’s growing renewable energy sector.
Immediate Expensing of U.S.-Based R&D and Equipment
Another major advantage under OBBBA is the ability to fully expense domestic research and development (R&D) costs in the year they are incurred. This reverses the prior rules that required businesses to amortize these expenses over several years, often slowing down innovation and increasing the financial burden of investment.
For foreign subsidiaries conducting R&D in the United States, particularly in Georgia, this change can make a substantial difference. By deducting costs immediately, companies can reinvest faster, accelerate product development, and support high-skilled job creation locally. In addition, OBBBA raises the Section 179 expensing limit for equipment purchases to $2.5 million, giving companies greater flexibility to write off the cost of machinery, technology, and other tangible assets in the first year.
It’s important to note that foreign-based R&D must still be amortized over 15 years, but when research activities are shifted to U.S. facilities, the new rules provide a direct and immediate benefit. For many international companies, this creates a strong incentive to establish or expand research operations in Georgia, where the combination of federal and state-level incentives can significantly reduce overall investment costs.
Strategic Advantages for Foreign Investors in Georgia
For international companies weighing their next expansion, Georgia offers more than just tax breaks. The state has long built its reputation as a business-friendly hub, and the new OBBBA provisions strengthen that position even further.
From a capital perspective, OBBBA’s accelerated deductions and credits can dramatically improve a project’s internal rate of return. That means companies can recoup investments faster and free up capital for reinvestment in growth. Georgia compounds this efficiency with its competitive state tax rates and robust incentive programs, including training funds, job tax credits, and infrastructure support.
The state’s strategic location also enhances supply chain reliability. By building in Georgia, foreign firms position themselves near major ports, airports, and interstates, ensuring faster delivery to customers across the U.S. while reducing exposure to international shipping risks. This supply chain proximity is especially valuable for industries such as electronics, clean energy, and advanced manufacturing, where speed and resilience are crucial.
Finally, Georgia’s collaborative business culture fosters strong partnerships between foreign and U.S. entities. Joint ventures allow international companies to tap into local knowledge, broaden their access to tax incentives, and mitigate regulatory risks, all while embedding themselves in a supportive ecosystem of suppliers, universities, and workforce development programs.
Turning OBBBA Into a Competitive Edge
The benefits of OBBBA are clear, but realizing them requires careful planning and execution. Foreign investors cannot assume eligibility or rely on general guidance alone; each project must be structured to align with both federal provisions and Georgia’s state-level programs.
For example, companies should evaluate whether their planned facilities and equipment meet the criteria for 100% bonus depreciation and confirm that construction timelines allow assets to be “placed in service” within the statutory deadlines. Clean energy developers should explore credit transferability options to ensure liquidity and consider how monetization strategies affect project financing. Meanwhile, all investors need to maintain compliance with international tax rules and remain alert to restrictions on Prohibited Foreign Entities, which could limit access to certain benefits.
In practice, this means working closely with legal and tax advisors who understand both U.S. federal rules and Georgia’s unique incentive framework. When done correctly, OBBBA doesn’t just reduce costs, it transforms Georgia into one of the most competitive destinations for foreign-owned facilities in the United States.
We Are Here to Help
BRAWW Law helps foreign investors navigate these complexities, structuring projects to maximize incentives, minimize risk, and secure long-term advantages in Georgia. If you’re considering a U.S. expansion, now is the time to explore how OBBBA and Georgia’s pro-business environment work together to create an exceptional landing spot for international investment.