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
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
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
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
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
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
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
As reported on May 13, 2025, several changes to the Washington state tax laws were passed by lawmakers and delivered to the desk of Governor Ferguson in late April, awaiting his signature to make them law. In the aggregate,...more
An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the disposition. See I.R.C. § 453. Under a standard installment sale, the buyer makes scheduled payments to...more
With the Canadian federal election just under two weeks away, the two major parties leading the current polls, the Liberals (led by Mark Carney) and the Conservatives (led by Pierre Poilievre), have yet to formally release...more
Just before the close of the 446th legislative session, the Maryland General Assembly passed and sent to Governor Moore HB 352/SB 321, the Budget Reconciliation and Financing Act of 2025 (the “BRFA”). The BRFA, which Gov....more
This article provides general information regarding U.S. federal income tax incentives available to non-corporate holders of “qualified small business stock” (“QSB stock”) as defined under Section 1202 of the Internal Revenue...more
KEY FACTS OF REAL ESTATE ACQUISITIONS UNDER BRITISH LAW - 1. Introduction - Historically, there has been significant investment by overseas individuals and corporations in real estate in England and Wales and in...more
The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...more
On February 6, 2025, President Donald Trump met with Republican lawmakers to discuss budget priorities, proposing to end carried interest. On the same day, Democrats introduced bills in both the House and the Senate that...more
On January 31, 2025, the Minister of Finance (Canada) announced that the proposed increase in the capital gains inclusion rate from one-half to two-thirds, previously intended to be effective for dispositions occurring on or...more
In recent years, the utilization of qualified small business stock (“QSBS”) has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section...more
In the Autumn 2024 Budget, the UK Government announced fundamental changes to the way that carried interest will be taxed in the UK. Major change in this area was expected and there will be a number of qualifying conditions,...more
1. Introduction - In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability...more
The "big ticket" item of the Tax Cuts and Jobs Act (TCJA) is the significant increase to the lifetime gift, estate and generation-skipping tax (GST) tax exemptions. Under the TCJA, the exemptions were increased from $5...more
President-Elect Donald Trump has not published a comprehensive tax plan as of the time of this writing, but he and Vice President-Elect J.D. Vance have made several proposals in campaign speeches, interviews and online....more
Types of business entities - The most common types of legal entities adopted in Argentina are the limited liability company (“Sociedad de Responsabilidad Limitada” or “SRL”), the corporation (“Sociedad Anónima” or “SA”)...more
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
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