On October 17, 2023, the Internal Revenue Service (IRS) updated the electronic signature guidance in its Internal Revenue Manual (IRM) to reflect the electronic signature relief that the IRS provided to taxpayers during the...more
In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more
6/16/2023
/ Acquisitions ,
C-Corporation ,
Capital Gains ,
Federal Taxes ,
Gain Exclusion ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Mergers ,
Qualified Small Business Stock ,
Shareholders ,
Small Business ,
State Taxes ,
Tax Planning
One of the headline tax changes in the Inflation Reduction Act of 2022, Public Law 117-169, is a 1% excise tax on stock repurchases by public companies. New Section 4501 of the Internal Revenue Code applies a non-deductible...more
1/13/2023
/ De Minimus Doctrine ,
Dividends ,
Excise Tax ,
Fair Market Value ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Leveraged Buyout ,
Liquidation ,
Loan buy-backs ,
Reorganizations ,
Stock Repurchases ,
U.S. Treasury
One of the headline tax changes in the Inflation Reduction Act of 2022, Public Law 117-169, is a 1% excise tax on stock repurchases by public companies. Public issuers should be aware that the new tax, which applies beginning...more
On Aug. 6, New York Attorney General Letitia James and D.C. Attorney General Karl Racine brought blockbuster lawsuits against the National Rifle Association and the National Rifle Association Foundation, alleging that these...more
Federal tax law changes enacted with the Tax Cuts and Jobs Act of 2017 may require tax-exempt organizations to reevaluate their compensation practices, particularly with respect to employee severance. Section 4960 of the...more