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Business Entities Taxation Internal Revenue Code (IRC)

Cadwalader, Wickersham & Taft LLP

Wyden’s Partnership Tax Bills: A Mouthful and Then Some

On June 17, 2025, Senator Ron Wyden introduced two extensive partnership tax reform bills in the Senate (collectively, the “Bills,” and available here and here).  The Bills expanded upon and incorporated many of Wyden’s 2021...more

Holland & Knight LLP

Conversion of Partnership and LLC Interests into Qualified Small Business Stock

Holland & Knight LLP on

Given the recent amendments to Internal Revenue Code Section 1202,1 which increase the benefits of holding qualified small business stock (QSBS), many companies currently operating as tax partnerships may want to convert into...more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

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