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Modified QOZ program delivers new investor incentives and permanence

The One Big Beautiful Bill Act (OBBBA) significantly modified the Qualified Opportunity Zone (QOZ) program via a set of comprehensive reforms aimed at improving accountability, long-term impact, and geographic equity. The new...more

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

Court Rules Taxpayer Can Offset Foreign Tax Credits With NIIT Liability Under Tax Treaty

In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...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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