The First 100 Days:

In the first few months of President Trump’s second term, a new wave of policy changes is starting to reshape the business landscape. From fluctuating tariffs and corporate taxes to workforce enforcement and regulatory rollbacks, the ripple effects are being felt across many sectors — especially by mid-to-large commercial enterprises.

Many of these early moves echo the priorities of the first Trump administration but with new scope and speed. Supply chains are tightening. Compliance rules are shifting. Talent pipelines are under pressure. For commercial leaders navigating complex operations, global exposure and cross-industry risk, staying ahead of these changes is critical.

In this article, we break down what’s changed so far, what it means for commercial businesses and what leaders should prepare for in the months ahead.

Trade Policy and Tariffs

President Trump’s second term has brought with it hardline trade policies with a renewed focus on tariffs to protect domestic industries. These changes are already impacting sourcing strategies, supplier relationships and cost structures for commercial businesses.

Key actions to date include:

• Escalation of China Tariffs: As of April 30, 2025, U.S. tariffs on Chinese imports now reach up to 145%, including new levies tied to national security and trade enforcement. China has responded with matching duties, raising costs and uncertainty for global supply chains. President Trump has said a deal is coming, but no specifics have been released.
• Expanded Global Tariffs and Pause: On April 2, 2025, the President announced new “reciprocal tariffs” on trade partners including Europe (20%), Japan (24%), Vietnam (46%) and more. Then, on April 9th, the administration unexpectedly paused most of the increases for 90 days, creating short-term relief and renewed trade uncertainty.
• New North American Trade Tariffs: Effective March 6, 2025, a 25% tariff was imposed on non-USMCA-compliant goods from Canada and Mexico, with a 10% tariff on certain energy and agricultural imports.
• Steel & Aluminum Tariffs: The U.S. imposed a 25% tariff on all steel and aluminum imports, removing country-based exemptions and prompting retaliatory measures from key partners.
• Ongoing Policy Uncertainty: The administration has signaled more tariff hikes may be coming, especially targeting strategic industries and supply chain dependencies.

For commercial businesses, these changes are creating strategic and financial pressure. Companies involving manufacturing, construction, and consumer goods are likely to see immediate impacts on cost structures — particularly those sourcing large volumes of raw materials like steel or aluminum. Tariffs on goods from China, Canada and Mexico are pushing enterprises to reevaluate global sourcing strategies and inventory planning, especially for just-in-time supply chains.

Additionally, the elimination of the de minimis rule — which previously allowed for duty-free import of low-cost goods — is increasing compliance and import costs for companies that rely on smaller, frequent cross-border shipments, particularly in logistics, retail and e-commerce operations.

Looking ahead, the administration has signaled continued movement on trade policy, with the potential for further adjustments to tariffs, USMCA enforcement and sector-specific trade negotiations. Commercial leaders should be prepared for a dynamic policy environment that may require fast adjustments to procurement, pricing and supplier relationships.

Key actions for commercial business leaders include:

• Evaluate tariff exposure across the supply chain. Prioritize cost modeling for high-volume imports and assess risk across current suppliers and regions.
• Engage in contract reviews. Negotiate long-term pricing agreements and flexibility clauses with global partners to hedge against future tariff hikes.
• Consider nearshoring or reshoring where feasible. Explore domestic or regional alternatives to reduce geopolitical and tariff-related risks.
• Establish scenario planning frameworks. Equip your supply chain and finance teams to model cost impacts under multiple trade policy outcomes.

Corporate Tax Shifts

The Administration has begun working on proposals aimed at lowering corporate tax rates and extending key provisions from the 2017 Tax Cuts and Jobs Act (TCJA), alongside a retreat from international tax agreements. For commercial enterprises, these moves could significantly impact investment planning, earnings strategy and global tax positioning.

Key actions to date include:

• Corporate tax cut: While campaigning, President Trump made clear his plans to reduce the corporate tax rate from 21% to 15% for U.S.-based manufacturers — a targeted incentive designed to encourage domestic production and the reshoring of industrial operations. April brought signs of renewed Republican focus, but lawmakers have not yet signaled how they plan to move forward.
• TCJA extension efforts: The Administration is pushing to extend business deductions and accelerated depreciation benefits originally scheduled to expire in 2026. While not yet finalized, early support in Congress suggests portions of the TCJA may remain in place beyond the current deadline.
• Withdrawal from the Organisation for Economic Co-operation and Development (OECD) global tax framework: The U.S. has formally stepped away from the OECD’s Pillar 1 and Pillar 2 global tax agreements, signaling a return to unilateral tax policy. This move adds complexity for multinational corporations with exposure to digital services taxes and minimum global tax requirements.
• Expanded Opportunity Zones: Lawmakers, including the House Ways & Means Committee, have proposed extending the Opportunity Zones program beyond 2026, potentially offering continued tax-advantaged investment options for commercial real estate and capital deployment in underdeveloped areas.

For commercial businesses, these shifts could create meaningful after-tax gains — particularly for capital-intensive industries like manufacturing, energy and logistics. Lower federal tax rates may improve cash flow and unlock capital for expansion or M&A activity. Businesses with significant domestic operations stand to benefit the most.

However, uncertainty remains. Without a finalized TCJA extension, planning for 2026 and beyond remains challenging. Meanwhile, the U.S. withdrawal from the OECD framework complicates tax compliance and risk management for global companies, particularly those with digital or IP-driven revenue streams.

Key actions for commercial business leaders include:

• Model scenarios for rate changes. Evaluate how a lower corporate tax rate would affect your long-term capital planning, cash flow and debt strategy.
• Stay engaged on TCJA developments. Review expiring provisions, particularly those involving depreciation, interest deductibility and R&D credits, and prepare for multiple outcomes.
• Review global tax exposure. Assess the potential impact of unilateral tax changes and international responses, especially for digital services or IP-rich business models.
• Explore Opportunity Zones. Revisit current or potential investments to determine if extended tax benefits could enhance long-term ROI.

Workforce and Immigration

The administration’s early workforce and immigration moves are reshaping labor dynamics across the country. For commercial businesses, especially those operating at scale or across state lines, these changes bring new challenges around staffing, compliance and long-term workforce planning.

Key actions to date include:

• Federal workforce reductions: The Department of Government Efficiency (DOGE) has significantly reduced headcount across agencies, including the Department of Labor and USDA, likely resulting in slower inspections, fewer compliance audits and reduced permitting staff.
• Stricter immigration enforcement: Immigration enforcement activity has ramped up under the new administration, leading to a reduced undocumented labor pool. At the same time, U.S. Immigration and Customs Enforcement (ICE) has increased the frequency of Form I-9 audits, placing greater scrutiny on workforce documentation and employer compliance.
• H-1B visa restrictions resurface as potential flashpoint: Under President Trump’s first term, H-1B denials surged and processing slowed due to increased scrutiny. While Trump now signals support, divisions in his administration raise the risk of renewed limits — especially for industries like tech and finance that rely on highly skilled foreign workers.
• E-Verify enforcement remains limited for now: While proposals like Project 2025 call for mandatory E-Verify, the system remains largely voluntary, and federal enforcement has been sparse so far. That could change quickly, creating compliance burdens for employers if mandates expand in industries like agriculture, construction and hospitality.

These developments are already impacting labor availability and compliance expectations. Industries that rely on immigrant or seasonal labor — including manufacturing, construction, agriculture, logistics and healthcare — may face tighter hiring pipelines and increased wage pressures. At the same time, stepped-up enforcement through I-9 audits and evolving visa rules may introduce new legal and administrative risks, particularly for firms with large or distributed workforces.

The reductions in federal staffing may also have knock-on effects for commercial operations that require government coordination — from environmental permitting and workforce training programs to procurement processes and federal contract administration. Slower turnaround times could delay projects or complicate compliance for heavily regulated industries.

Commercial employers should be prepared for evolving enforcement, especially as new policies take hold across states and federal agencies. With additional workforce-related executive actions expected in the coming months, business leaders should stay alert to regulatory changes, audit trends and immigration-related risk exposure.

Key actions for commercial business leaders include:

• Prepare for audit risk. Review I-9 documentation processes and ensure HR teams are trained on compliance as ICE audit activity increases.
• Monitor visa policy developments. If your business relies on high-skilled foreign workers, stay alert to potential changes in H-1B rules or processing timelines.
• Evaluate labor exposure. Assess how immigration enforcement and workforce reductions could impact hiring, turnover, or wage pressures in your industry.
• Track E-Verify developments. While not currently mandatory, proposals for expanded enforcement could increase compliance obligations — especially in labor-intensive sectors.
• Factor in permitting and oversight delays. Reduced federal agency staffing could slow inspections, certifications and project approvals in regulated industries.

Energy and Environmental Policy

The administration’s early environmental agenda has focused on deregulation and energy expansion, offering potential cost relief for industrial and logistics-heavy businesses. However, looser oversight and long-term climate uncertainty present tradeoffs, especially for companies with ESG commitments or regulatory exposure at the state or international level.

Key actions to date include:

• Withdrawal from the Paris Agreement: The U.S. has formally exited the global climate accord, reducing pressure on federal agencies to meet emission reduction targets and signaling a shift away from coordinated international climate efforts. For commercial businesses, this may ease federal compliance burdens but create misalignment with international partners and investor expectations around sustainability reporting.
• Rollbacks on emissions and efficiency standards: The EPA has paused or reversed rules covering standards such as tailpipe emissions, industrial carbon output and appliance efficiency — particularly benefiting automotive, logistics and manufacturing sectors.
• Energy expansion measures: The administration has opened new federal lands for oil and gas development and eased permitting rules for infrastructure projects tied to fossil fuels.
• Suspended enforcement at key agencies: Budget and staffing cuts at the EPA and Department of Energy are likely to slow regulatory enforcement and delay environmental reviews for large-scale commercial development.

Industries with large energy footprints — such as transportation, construction and heavy manufacturing — may benefit from near-term cost savings due to lower fuel prices, fewer emissions penalties, and relaxed operational constraints. Businesses engaged in domestic energy production or infrastructure development may also find new growth opportunities under the new agenda.

However, companies with ESG strategies, long-term climate goals or operations in states with stricter environmental standards may face growing complexity. Multinational firms must also navigate divergence between U.S. policy and international climate frameworks, which could affect reporting requirements, capital access or investor scrutiny.

Key actions for commercial business leaders include:

• Assess energy cost impacts: Reevaluate fuel and utility budgets in light of potential reductions in regulatory and compliance costs.
• Revisit infrastructure and development timelines: Loosened permitting rules may accelerate construction schedules — explore whether stalled projects can now proceed faster.
• Align ESG reporting strategy: For businesses with sustainability goals, prepare for divergence between U.S. deregulation and stricter global or state-level standards.
• Monitor enforcement changes: Track EPA and DOE staffing and rule changes that may alter how environmental audits, reviews or penalties are handled.
• Evaluate domestic energy partnerships: Companies in logistics, manufacturing or development may benefit from expanded U.S. oil and gas activity — review upstream and downstream supplier opportunities.

How Commercial Businesses Can Stay Ahead

Policy shifts can create disruption, but they also create opportunity. Commercial businesses need clear, proactive strategies to navigate uncertainty and position themselves for growth.

Here are broad-based strategies leaders can use to stay one step ahead:

• Reassess global supply chains. Tariffs and shifting trade relationships mean it’s time to evaluate sourcing strategies, explore nearshoring options and build greater supply chain resilience.
• Build flexible tax and investment plans. With corporate tax cuts on the table and the future of the TCJA still undecided, companies should work closely with tax advisors to plan for multiple outcomes — and move quickly when policy solidifies.
• Review immigration and hiring policies. Tighter enforcement and policy uncertainty make workforce planning more complex. Companies should audit their employment documentation practices and develop contingency plans for hard-to-fill roles.
• Track regulatory and permitting timelines. Federal agency staffing cuts may delay inspections and approvals. Businesses should account for these slowdowns in expansion, construction or compliance timelines.
• Update sustainability strategies. With the rollback of federal climate commitments, commercial businesses — especially those with global footprints or ESG obligations — should proactively align with state and international standards.
• Engage policy and legal advisors. The pace of change is accelerating. Leaders need trusted partners to help assess risks, capitalize on incentives and stay compliant across jurisdictions.

The landscape is shifting. Comerica can help you navigate what’s next. Visit Comerica Insights for ongoing updates and guidance.

The views expressed are those of the author at the time of writing and are subject to change without notice. We do not assume any liability for losses that may result from the reliance by any person upon any such information or opinions. This material has been distributed for general educational/informational purposes only and should not be considered as investment advice or a recommendation for any particular security, strategy or investment product, or as personalized investment advice.