Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
2021 House Ways And Means Tax Proposals
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
Qualified Opportunity Zone Fund Investments
The Opportunity Zone regime, originally established in 2017, has been permanently extended by Public Law 119-21, "An Act to provide for reconciliation pursuant to Title II of H. Con Res. 14" (the "2025 Tax Law"). The...more
The regime sets new rules regarding the taxation of gains realized on the sale of securities held by employees or executives in the frame of management packages....more
The One Big Beautiful Bill Act (the “OBBBA”), which was signed into law on July 4, 2025, contained a big, beautiful surprise for qualified small business stock (“QSBS”) investors. Individual investors, private equity funds...more
Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more
In Haworth v HMRC [2025] EWCA Civ 822 (Haworth) the UK Court of Appeal (CoA) provided much needed clarity regarding the approach to determining the ‘place of effective management’ (POEM) in the context of the UK’s double tax...more
On July 4, 2025, the One Big Beautiful Bill Act (the "OBBBA") was signed into law. The OBBBA made a number of significant changes to the Internal Revenue Code of 1986, as amended (the "Code"). We write to highlight a handful...more
Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more
The BC Court of Appeal decision in Dignard v Dignard, 2025 BCCA 43, gave clarity as to what considerations are needed when deciding whether an equal division of property would result in significant unfairness. The Court...more
The One Big Beautiful Bill Act (OBBBA) made the following changes to qualified small business stock (QSBS): The holding period is now graduated for stock acquired after July 4, 2025....more
The One Big Beautiful Bill Act (“OBBBA”) was recently signed into law on July 4, 2025. One of the changes to the tax code in the OBBBA impacts qualified small business stock (“QSBS”) under Section 1202. The changes generally...more
On July 21, 2025, HM Revenue and Customs (HMRC) published the long-awaited draft legislation (Draft Legislation) for the new UK carried interest tax regime (New Regime) that will apply from April 6, 2026. Under the New...more
Prior to the One Big Beautiful Bill Act signed by President Trump on July 4, 2025 (the “OBBBA”) , Section 1202 provided that non-corporate taxpayers that acquired qualified small business stock after August 10, 1993 (“QSBS”)...more
Key Takeaways: - On July 4, 2025, “The One Big Beautiful Bill Act” (the “Act”) was signed into law, introducing significant expansions of the tax benefits of “qualified small business stock” (“QSBS”) issued on or after July...more
In late 2024, the Internal Revenue Service (IRS) introduced Form 15620 to provide a standardized mechanism for taxpayers to make elections under Section 83(b) of the Internal Revenue Code (the “Code”). More recently in 2025,...more
On July 10, 2025, Missouri Governor Mike Kehoe signed House Bill 594 into law, amending RSMo. § 143.121 to exempt capital gains from its existing state income tax. For tax years beginning on or after January 1, 2025, income...more
A recent district court ruling broadened the interpretation of the statutory provisions governing exemptions from land appreciation tax and ruled that transfers of shares of a real estate association as a gift between...more
On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA), the most significant US tax overhaul since the 2017 Tax Cuts and Jobs Act (TCJA). The OBBBA includes critical changes impacting family offices,...more
On July 4, 2025, President Trump signed the "One Big Beautiful Bill Act" (the “OBBBA”), which contains amendments to sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code (the “Original Statute”)—the provisions that...more
Welcome to the June edition of our UK Tax Round Up, which discusses HMRC’s response to its consultation on the new UK carried interest regime to be introduced next year and interesting cases on the main purpose test in the...more
The 89th regular session of the Texas Legislature has voted to put some proposed constitutional amendments relating to state taxation on the ballot for the election on November 5, 2025. Let’s take a look....more
Orrick's Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of our...more
Anticipated to be finalized and adopted in July 2025, the new tax reforms for Kazakhstan would go into effect in January 2026. This LawFlash summarizes the taxation of income from capital gains when selling shares and...more
Filing your 2024-25 Self-Assessment return early means faster refunds, better budgeting, and no deadline stress. Do not delay, start gathering your tax details today....more
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