Tax changes for accelerated depreciation creating incentive for Wyoming projects

March 2026 analysis from the Jackson Hole Investor Group

The sunsetting of renewables tax credits under OBBBA has been widely covered, but the impacts of changes to depreciation rules may be less appreciated. By allowing 100% first-year write-offs for investments such as refinery buildings and sub-surface mining equipment, the tax code changes have helped to de-risk the large upfront capital expenditures required to build domestic supply chains. Wyoming’s unique geology and existing infrastructure base have made it a target for eligible projects including critical minerals mining/refining and advanced nuclear development. This benefits legacy efforts and has triggered new investments to capture the full immediate deduction before scheduled phase outs.

Delving deeper, OBBBA legislation enacted in July 2025 permanently restored 100% bonus depreciation for equipment and introducing a breakthrough "Qualified Production Property" (QPP) rule. This provision allows companies to immediately expense the full cost of not just machinery, but also the physical structures of new manufacturing and refining facilities, provided construction begins before 2029 or is completed in the following year. Furthermore, the Act expanded interest deductions to help heavy asset, high debt projects which can significantly lower the cost of capital.

The OBBBA accelerated the phase-out of wind and solar tax credits and expanded Foreign Entity of Concern restrictions to battery components and other clean energy supply chain materials across additional tax credit categories. However, the Act maintained a 10% Energy Community Bonus Tax Credit for renewables projects able to meet the accelerated timetable. Also, it preserved full incentives for other clean tech including nuclear, geothermal, carbon capture, and advanced manufacturing (ex-wind).

Specific investment activity in Wyoming since the bill's passage includes: Ramaco Resources Brook Mine rare earth mine and pilot processing plant in mid-2025 and American Rare Earth’s Halleck Creek project which achieved a key processing milestone in December. BWXT will receive $100M in state funds for its investment in a Gillette TRISO nuclear fuel facility, while pre-planned TerraPower nuclear reactor saw continued advancement. Traditional players are also pivoting; Peabody Energy named for a $6.25 million Wyoming grant in early 2026 to pilot rare earth extraction from coal, while Carbon GeoCapture and Black Hills Energy launched a state-backed project to store CO2 in coal seams. In the fossil fuel sector, Continental Resources is considering a large expansion of Niobrara and Mowry Shale oil development. In renewables, Repsol Renewables is hoping to complete the $500 million Rail Tie Wind project by late 2026 while Enbridge is moving forward with its $1.2 billion Cowboy Solar initiative to meet the surging power demands of regional AI data centers before the OBBBA's accelerated credit deadlines. Meanwhile, the recently rebranded Pronghorn Project (formerly including hydrogen production) and Laramie Range Wind project (dubbed “wind wall” by local opponents) are stalled due to a host of local concerns and permitting issues.