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Capital Gains Tax Capital Gains

Seward & Kissel LLP

New Rules for Qualified Small Business Stock in 2025

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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

Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on

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

Cozen O'Connor

When Is Equal Property Division Unfair in BC? Court of Appeal Offers New Guidance

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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

Bilzin Sumberg

Section 1202 – Enhanced Opportunities in Increased Exclusions and Caps

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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

Husch Blackwell LLP

Missouri Eliminates Tax on Capital Gains

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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

Barnea Jaffa Lande & Co.

Sibling Share Transfers Tax-Exempt—even via Parents

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

Goodwin

A New Form Section 83(b) Election: IRS Form 15620

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As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) elections are frequently...more

Foster Garvey PC

What Is Likely the Last Chapter in the Wild Journey of the Washington State Capital Gains Tax Occurred on November 5, 2024, With...

Foster Garvey PC on

The Wild Journey - I am taking time out from my multi-part series on Subchapter S to report on the Washington capital gains tax. As you know, I have reported in several prior blog posts on the numerous challenges...more

Barnea Jaffa Lande & Co.

New memorandum of law regulating the crypto sector in Israel

Barnea Jaffa Lande & Co. on

The Israel Tax Authority and the Ministry of Finance have published a memorandum of law to regulate the digital asset sector in Israel. This memorandum recognizes digital assets for the first time as capital assets subject to...more

Stark & Stark

Dividing Cryptocurrency in a New Jersey Divorce: What You Need to Know

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Cryptocurrency has become an increasingly popular investment and asset class in recent years. As digital currencies like Bitcoin, Ethereum, and others continue to gain mainstream acceptance, they are also becoming more common...more

Goodwin

Key Takeaways from the Autumn Budget 2024

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Rachel Reeves, the first female Chancellor of the Exchequer in the role’s 800-year history, delivered Labour’s first budget in 14 years on the 30th October. We have set out below a brief summary of some of the tax measures...more

BCLP

Autumn Budget 2024 - 10 Key Tax Points for Business

BCLP on

Yesterday, 30 October 2024, the Chancellor announced that the Autumn 2024 budget will raise taxes by £40bn, the biggest raise since 1993. While the Autumn budget arguably does not portray as pessimistic an outlook for...more

Morgan Lewis

UK Government Updates Tax Regime for Carried Interest

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As part of the Autumn Statement, the UK government on 30 October 2024 announced a reform of its taxation of carried interest. This follows a call for evidence on the reform of the UK taxation treatment of carried interest in...more

Cadwalader, Wickersham & Taft LLP

The UK Government’s Autumn Budget 2024

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2024 on 30 October 2024. The Budget was the first to be delivered by the new Chancellor of the Exchequer, following the election of the Labour...more

BCLP

Autumn Budget 2024 - What’s the Tax Impact on the Real Estate Sector?

BCLP on

The real estate sector was not ignored by Budget announcements today. There were no seismic changes – the changes announced were less impactful than the speculation in the weeks preceding the Budget....more

Orrick, Herrington & Sutcliffe LLP

Legal Ninja Snapshot: #ESOP & Flips — U.S. ESOPs May Become Available for the Employees of the German Subsidiary

Much has been written about the unsatisfactory tax situation of German employees when it comes to equity-based employee stock (option) programs ("ESOP"). Historically, employees were taxed at the time of issuance of shares...more

Saul Ewing LLP

The Incomparable IDGT: The Gift That Keeps on Giving

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When creating trusts for estate-reduction purposes, nothing compares to the Intentionally Defective Grantor Trust.  This type of trust is referred to by the acronym “IDGT.” Called by some as an I-D-G-T and others a word that...more

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

DLA Piper on

The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Foster Garvey PC

The Newest Chapter in the Tumultuous Journey of the Washington State Capital Gains Tax – Judge Allyson Zipp Rules From the Bench

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As reported last week, opponents of the Washington state capital gains tax, after ultimately losing in the courts to have the legislation stricken as unconstitutional, decided to take the matter to the voters. They have...more

Foster Garvey PC

The Tumultuous Journey of the Washington State Capital Gains Tax Continues

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I have reported in several prior blog posts the significant events impacting the newly enacted Washington state capital gains tax. The turbulent ride of this legislation continues!...more

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Foley & Lardner LLP

Thinking About Selling your Business? Now is the Time

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The economic environment has mostly stabilized following the inflationary shocks of 2021-2022, and a strong Q4 2023 suggests that M&A may be in line for a comeback in 2024. The following trends demonstrate why now is likely a...more

Venable LLP

Earnouts and Their Tax Treatment

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As buyers and sellers engage in negotiations for the sale of a business, often there may be disagreements as to the value and expected growth of that business. One party might currently value the business higher than the...more

Proskauer - Tax Talks

Change to non-domicile tax regime forms part of UK Spring Budget 2024

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As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more

DarrowEverett LLP

How Bonus Depreciation Can Be A Timely Tool in Real Estate Deals

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So, you’re a real estate investor accustomed to tax mitigation strategies and you are starting to think about your next big project. With that comes so many streams of thought — location, timing, interest rates, partnerships,...more

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