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
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). The House Bill will next be considered by the U.S. Senate, and the administration has set a...more
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
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
On May 12, 2023, the Internal Revenue Service (IRS) published private letter ruling 202319013 (the PLR), which concluded that an enterprise cloud application software company is engaged in a qualified trade or business for...more
Since December 22, 2017, corporate tax practitioners in the United States have been predominantly focused on the impact of legislation commonly known as the Tax Cuts and Jobs Act (the “Act”), which was signed into law on that...more
9/6/2019
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Corporations ,
Foreign Earned Income ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Tax Treaty ,
U.S. Treasury
On July 11, 2018, the U.S. Treasury Department and the Internal Revenue Service (the IRS) issued final regulations under Section 7874 and related sections of the Internal Revenue Code of 1986, as amended, (the Code)...more
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more
On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice), which provides guidance addressing the so-called "transition tax" or "toll charge" described in...more
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
On July 14, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 355 of the Internal Revenue Code that would establish new guidelines under the so-called "device" and "active business" tests....more
7/21/2016
/ Active Business Test ,
Alibaba ,
Control Test ,
Device Test ,
Internal Revenue Code (IRC) ,
Proposed Regulation ,
Recapitalization ,
Revenue Procedure 2016-40 ,
Share Classes ,
Tax-Free Spin-Offs ,
U.S. Treasury ,
Yahoo!
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
4/22/2016
/ Conversion ,
Convertible Debt ,
Corporate Issuers ,
Dividends ,
Foreign Persons ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Reporting Requirements ,
Shareholder Distributions ,
Shareholders ,
Stocks ,
U.S. Treasury ,
Withholding Requirements
Legislation signed by President Obama on December 18, 2015, makes permanent a U.S. federal income tax exclusion from gross income of 100 percent of the gain recognized by non-corporate taxpayers on the sale or exchange of...more