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One Big Beautiful Bill Act brings major changes to Section 1202 capital gains exclusion

The recently passed One Big Beautiful Bill Act (OBBBA) makes significant and immediate changes to the tax rules surrounding qualified small business stock (QSBS) under Section 1202 of the Internal Revenue Code. These rules...more

How Cross-Border M&A May Be Impacted by Trump Administration Tax Reform

President-elect Donald Trump is set to return to the White House with Republicans narrowly securing both the US Senate and the US House of Representatives. Having control of both chambers positions the party well to pursue...more

Guidance in Proposed Regulations Expected to Jumpstart the Benefits of Qualified Opportunity Zone Investing

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions as an incentive for taxpayer investment in low-income neighborhoods and combined the benefits of both tax deferral and tax elimination. On October 19,...more

The New Participation Exemption: An Opportunity to Convert Ordinary Dividends into Qualified Dividends

The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more

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