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New Electronic Filing Option for Section 83(b) Elections

On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

New Jersey Adopts QSBS Exclusion: A Game-Changer for In-State Investors and Founders

On June 30, 2025, New Jersey enacted legislation that now incorporates the US federal qualified small business stock (QSBS) rules under Section 1202, effective for dispositions of QSBS for tax years beginning on or after...more

The One Big Beautiful Bill Act Signed into Law: Tax Implications at a Glance

Following our prior alerts on each of the House Ways & Means Committee and Senate Finance Committee versions of the One Big Beautiful Bill Act (OBBBA), the Senate passed its version of the OBBBA on July 1, 2025, returning the...more

Senate Finance Committee’s Take on the One Big Beautiful Bill Act

Following our prior alert on the House Ways & Means Committee version of the One Big Beautiful Bill Act (“OBBBA”), the House passed its version of the OBBBA (“House Bill”) on May 22, 2025, and on June 17, 2025 the Senate...more

Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

Tax Reform 2.0 — The One, Big, Beautiful Bill

On May 12, 2025, the House Ways and Means Committee released the text of the proposed tax legislation titled “The One, Big, Beautiful Bill” (the “Bill”), reflecting President Trump’s and the Republican Party’s legislative...more

Proposed Treasury Regulations Provide Guidance on Stock Buyback Excise Tax for Redemptions and M&A Transactions

On April 12, 2024, the Treasury Department and Internal Revenue Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing comprehensive guidance for applying the one-percent excise tax owed on corporate...more

Energy & Sustainability Legal Feature – Increased Opportunity for More Taxpayers to Access Clean Energy Tax Credits and Related...

This past summer, the Treasury and Internal Revenue Service (IRS) published proposed Treasury Regulations (88 FR 40528 and 88 FR 40496) under two key provisions of the Inflation Reduction Act of 2022 (IRA) designed to enable...more

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