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Capital Gains Tax Capital Gains Income Taxes

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

Bilzin Sumberg

Section 1202 – Enhanced Opportunities in Increased Exclusions and Caps

Bilzin Sumberg on

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

Goodwin

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

Goodwin on

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

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

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

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

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

Proskauer - Tax Talks on

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

Harris Beach Murtha PLLC

Massachusetts Tax Law Update - May 2023

On April 13, the Massachusetts House of Representatives approved H.3770, a tax reform bill that includes significant changes for individuals, businesses and estates. The bill is now with the Senate’s Ways and Means Committee,...more

Perkins Coie

Washington Capital Gains Tax: More Questions, Tentative Answers

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Nearly two years after being enacted by the state legislature, and one year after being struck down by a lower court, the Washington state capital gains tax has been reinstated as constitutional, and the first returns and...more

Miller Nash LLP

Washington’s New Capital Gains Excise Tax: An Income Tax by Another Name

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The Washington State Supreme Court recently upheld an excise tax on the privilege of selling capital assets within the State of Washington. The Court upheld the new tax over concerns that the tax violated both the state and...more

McDermott Will & Schulte

Washington State Capital Gains Tax Upheld; Payments Due April 18

The amount of taxes due this year for many Washington state taxpayers just increased following a 7-2 decision from the Washington Supreme Court in which it reversed a lower court’s ruling and held that the state’s new capital...more

Foster Garvey PC

When It Rains, It Pours in Washington State – The Washington Supreme Court Upholds the 2021 Enacted Capital Gains Tax

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It is a rainy day in the Pacific Northwest with chances of snow showers. For those taxpayers that reside in the state of Washington or own highly appreciated capital assets located in the state, their day just got a bit...more

Bowditch & Dewey

How Can I Have Capital Gains Tax When My Mutual Fund Lost Money?

Bowditch & Dewey on

Many mutual fund investors have seen their mutual fund investments drop 30% or more in 2022. The Fidelity Growth Company Fund (FDGRX) is down 33.78% for 2022. The Vanguard US Growth Fund Investor (VWUSX) is down 39.64%....more

Morgan Lewis

Planning for the Massachusetts ‘Millionaires Tax’

Morgan Lewis on

The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more

Poyner Spruill LLP

Planning to Exclude Gain on Sale of Corporate Stock

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When incorporating a business, you may form a C corporation or S corporation.  If you choose a C corporation, consideration should be given to qualifying the stock as “qualified small business stock” (“QSBS”)....more

Stoel Rives LLP

Court Reviews New Washington Capital Gain Tax

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Effective January 1, 2022, Washington imposes an excise tax on an individual’s long-term capital gains from the sale of stock, bonds, and other assets exceeding $250,000 if the assets were located in Washington at the time of...more

Foster Garvey PC

Taxpayers Take a Hit in the Washington Capital Gains Tax Battle

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By motion dated November 3, 2022, the Washington State Attorney General asked the Supreme Court of the State of Washington to allow the Washington Department of Revenue to implement and collect the capital gains tax struck...more

Katten Muchin Rosenman LLP

Greener Pastures: Five Things to Consider When Leaving One Jurisdiction for Another

Is the grass always greener on the other side? Like any major life decision, deciding to uproot yourself (and potentially your family) and move from one state to another is not an easy decision. Although laws, taxes and...more

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