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The One Big Beautiful Bill: Extending the TCJA and Curtailing the IRA

On May 22, 2025, the U.S. House of Representatives approved H.R. 1, also known as the “One Big Beautiful Bill Act” (the House Bill).1 The House Bill will next be considered by the U.S. Senate. The House Bill includes a number...more

Understanding Section 1202: The Qualified Small Business Stock Exemption

The “qualified small business stock” (QSBS) tax exemption under Section 1202 allows non-corporate founders and investors in certain emerging growth companies to potentially exclude up to 100 percent of the U.S. federal...more

Eligibility of Life Sciences Companies for Qualified Small Business Stock

The “qualified small business stock” (QSBS) tax exemption under Section 1202 of the Internal Revenue Code allows non-corporate founders and investors in certain emerging growth companies organized as corporations to...more

Treasury and IRS Release Proposed Regulations Regarding Reporting Requirements for Digital Asset and Cryptocurrency Transactions

On August 25, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released proposed regulations regarding information reporting, determination of amount realized and basis, and backup...more

The New One-Percent Excise Tax on Stock Repurchases and Its Potential Implications for Convertible Bond Hedge Transactions and...

On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more

House Democrats Propose to Limit Qualified Small Business Stock Tax Exemption

On September 13, 2021, Democrats on the House Ways and Means Committee released proposed tax legislative text as part of a broader $3.5 trillion budget proposal. Among the proposals is a substantial limitation of the...more

California Budget Proposal Includes Temporary Suspension on Use of NOLs and Limitations on Use of Business Credits

On June 3, 2020, lawmakers in California announced that they have reached a budget agreement that includes a number of California income tax changes previously proposed by California Governor Gavin Newsom, including a...more

COVID-19 Tax Relief: Congress Enacts Federal Income Tax Relief for Businesses

As part of the U.S. government's response to the economic disruption caused by the Novel Coronavirus (COVID-19), on March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (H.R. 748 or the CARES Act) was...more

Tax Relief Under the CARES Act

On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), a $2 trillion stimulus package thought to be the largest in U.S. history. The CARES Act contains several key...more

IRS Issues Proposed Regulations Reducing Income Inclusions under Section 956 for Certain U.S. Corporations

On October 31, 2018, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations (the "Proposed Regulations") that would generally reduce the amount that a corporate U.S. shareholder is required...more

House Committee on Ways and Means Releases Tax Cuts and Jobs Act

On November 2, 2017, the House Committee on Ways and Means, led by Republican Chairman Kevin Brady, released H.R. 1, the "Tax Cuts and Jobs Act." The House Committee is expected to mark up the bill beginning on November 6,...more

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

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