As part of the newly enacted One Big Beautiful Bill Act (the OBBBA),[1] Congress adopted the first substantive amendments to Section 1202[2]–which prescribes the qualified small business stock (QSBS) rules–in over a decade...more
7/10/2025
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment ,
New Legislation ,
New Regulations ,
Qualified Small Business Stock ,
Shareholders ,
Small Business ,
Tax Credits ,
Tax Planning ,
Tax Reform ,
Taxation
Share on LinkedIn Share on Twitter Print Share by Email Share Back to top Last month, YA Global Investments, LP (the “Fund”) filed a notice of appeal to the U.S. Court of Appeals for the Third Circuit, seeking review of the...more
Withholding Under Code Sections 1446(a) and 1446(f)
A partnership, such as a fund treated as a partnership for U.S. federal income tax purposes, that realizes income effectively connected with the conduct of a trade or...more
One of the lesser-known yet very beneficial provisions of the Internal Revenue Code (the Code) relating to business investment is Section 1202. Originally passed in 1993 and amended several times over the years, Section 1202...more
On July 27, 2022, Senate Majority Leader Chuck Schumer (D-N.Y.) and Senator Joe Manchin (D-W.Va.) released preliminary details of a bill, named the Inflation Reduction Act of 2022, to address climate change, taxes, health...more
8/1/2022
/ Adjusted Gross Income ,
Capital Gains ,
Climate Change ,
Healthcare ,
Holding Periods ,
Interest Rates ,
Internal Revenue Code (IRC) ,
Investment Adviser ,
Price Inflation ,
Proposed Rules ,
U.S. Treasury
On July 16 and 17, 2019, the U.S. Senate approved resolutions of ratification of protocols to amend existing income tax treaties between the United States and various countries, including Spain, Japan, and Switzerland. Before...more
On July 13, 2017, the U.S. Tax Court issued a decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, which could have a significant impact on how non-U.S. investors invest in U.S....more
A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more
3/15/2017
/ Appeals ,
Corporate Taxes ,
Dividends ,
Domestic International Sales Corporation ,
Holding Companies ,
Internal Revenue Code (IRC) ,
Reversal ,
Roth IRA ,
Shareholders ,
Substance Over Form Rule ,
Tax Court ,
Transfer Pricing