Given the recent amendments to Internal Revenue Code Section 1202,1 which increase the benefits of holding qualified small business stock (QSBS), many companies currently operating as tax partnerships may want to convert into...more
8/4/2025
/ Business Entities ,
C-Corporation ,
Corporate Conversions ,
Holding Periods ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
Partnerships ,
Qualified Small Business Stock ,
Small Business ,
Tax Legislation ,
Tax Planning ,
Taxation
In order for stock to be qualified for an exclusion on gain under Internal Revenue Code (Code) Section 1202, the issuing corporation must, among other requirements, have aggregate gross assets of no more than $75 million at...more
Section 1202 of the Internal Revenue Code provides that noncorporate taxpayers may exclude certain gains on the disposition of Qualified Small Business Stock (QSBS) held longer than the minimum required holding period. One...more
7/21/2025
/ Capital Gains ,
Conversion ,
Corporate Taxes ,
Exclusions ,
Internal Revenue Code (IRC) ,
Mergers ,
Partnerships ,
Qualified Small Business Stock ,
Small Business ,
Stock Transfer ,
Tax Benefits ,
Tax Deductions ,
Tax Planning ,
Taxation ,
Venture Capital
President Donald Trump on July 4, 2025, signed into law H.R. 1, commonly referred to as the One Big Beautiful Bill Act (OBBB). (For a detailed analysis of the bill, see Holland & Knight's previous alert, "Trump Signs the One...more
In a significant win for taxpayers, the U.S. Tax Court recently ruled in AbbVie Inc. v. Commissioner, Docket No. 2597-23, that a $1.6 billion "Break Fee" paid by AbbVie qualifies as an ordinary and necessary business expense...more
6/30/2025
/ AbbVie ,
Break-Up Fee ,
Capital Losses ,
Contract Disputes ,
Cooperation Agreement ,
Corporate Taxes ,
Fees ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Tax Court ,
Tax Deductions ,
Tax Planning
As of June 12, 2025, individuals and businesses can register to receive information on the Trump Gold Card – a proposed alternative or possible replacement to the EB-5 visa, also known as the Immigrant Investor Visa. ...more
More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more
The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more
The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more
1/13/2023
/ C-Corporation ,
Comment Period ,
Domestic Partnership ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
Shareholders ,
Side Letters ,
U.S. Treasury
The coronavirus (COVID-19) health crisis and associated economic downturn is expected to have a significant impact on commercial real estate lessees, as their ability to attract in-person customers and otherwise generate...more