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Senate Bill Would Augment QSBS Benefits for Startup Company Investors

The Senate Finance Committee's version of the Republicans' budget reconciliation legislation (the “Senate Bill”) would significantly expand the qualified small business stock (QSBS) benefits under Section 1202 of the Code...more

House Reconciliation Bill Would Restore Expensing for Domestic R&D Prospectively

On May 22, 2025, the U.S. House of Representatives passed a reconciliation bill (commonly referred to as the “One Big Beautiful Bill”), which would restore expensing for domestic research and development expenses incurred in...more

Treatment of Capitalized R&D Costs under Section 174 on a Disposition of IP: The Other Shoe to Drop

One of the more significant issues that taxpayers and tax practitioners have faced in recent months is the Tax Cuts and Jobs Act’s (TCJA) amendment to Section 174, requiring capitalization of previously deductible R&D and...more

U.S. Tax Legislation Alert: Wyden Bill Proposes…

Last month, Senate Finance Committee Chair Ron Wyden of Oregon and fellow Finance Committee Democrats Sherrod Brown of Ohio and Mark Warner of Virginia released a draft proposed overhaul of the international tax regime (the...more

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