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Changes to QSBS Rules

As if QSBS wasn’t good enough already, the “Big Beautiful Bill” signed into law by President Trump on July 4, 2025 enacts significant, founder-friendly changes to Section 1202 of the Internal Revenue Code, which substantially...more

Section 83(b) Elections — Should You Pay Taxes Now?

In startups and early-stage companies, founders often receive restricted equity grants as compensation for their services. With some planning, founders can potentially lower the taxes they pay on the appreciation of the...more

Cross-Border Issues for Founders with U.S. Companies

We encounter many founders who have based their enterprises in the U.S., but who are not U.S. citizens or permanent residents, or who may have other significant cross-border ties such as close family living outside the U.S....more

QSBS Rollovers

Most founders are familiar with Section 1202 of the Internal Revenue Code, which provides a tax exemption for the sale of Qualified Small Business Stock (QSBS).  Less well known is Section 1202's cousin, Section 1045, which...more

Introducing the GOAT Trust

The menu of tax planning options for founders includes many strategies designed to minimize income taxes upon liquidity events and to provide for wealth preservation across multiple generations. To achieve those benefits,...more

Donations of Private Stock: Timing is Everything

The ability to receive an income tax deduction for donations of private company stock can be a useful tax planning tool for founders. Assuming the stock has been held for more than one year, a founder can generally deduct the...more

Tax Benefits of Advance Planning

Estate planning strategies for founders are typically focused on saving both income taxes and estate taxes. Income tax savings can be achieved by creating and funding multiple trusts with company stock that duplicate any...more

Effect of the Tax Cuts and Jobs Act on Trust and Estate Planning

The Tax Cuts and Jobs Act, signed into law on December 22, 2017, includes significant changes to the U.S. federal gift, estate, and generation-skipping transfer (GST) tax laws, effective as of January 1, 2018. In addition,...more

Federal Tax Reform May Affect Estate Planning

On November 2, the House Ways and Means Committee released a draft tax reform bill known as the Tax Cuts and Jobs Act. The Senate Finance Committee followed on November 9 with its own outline for tax reform legislation. Both...more

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