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Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more
On July 10, 2025, Missouri Governor Mike Kehoe signed into law House Bill 594 (the “Bill”), which effectively eliminates the capital gains income tax for individuals and an income tax deduction for corporations. Capital gains...more
In a recent post, available here, we discussed the basic requirements and benefits of Internal Revenue Code Section 1202, which provides for the exclusion from income of certain gains realized with respect to the sale of...more
The One Big Beautiful Bill Act (OBBBA), enacted July 4, 2025, made a number of changes to the Internal Revenue Code of 1986, as amended (the Code), including certain notable changes to the provisions of Code Section 1202 for...more
In this fifth installment of my multi-part series on the One Big Beautiful Bill Act, Steve Nofziger and I discuss a provision of the Act that impacts certain business owners who are contemplating a sale of their shares, Code...more
The qualified small business stock (QSBS) rules can be a powerful tax planning tool, and, following the recent enactment of a signature tax law, they have become even more potent....more
Entrepreneurs and investors should consider significant changes to the rules governing qualified small business stock (QSBS) included in H.R. 1, often referred to as the “One Big Beautiful Bill” (OBBB). The OBBB was passed...more
Many Massachusetts residents have recently considered taking, or have undertaken, steps to relocate from Massachusetts to jurisdictions with lower or no state income taxes, especially in light of the recently enacted 2023...more
Thanks to three primary revenue bills that were signed into law earlier this year, taxes are going up in the state of Washington, in particular for large service businesses, estates and individuals earning capital gains. ...more
On July 10, 2025, Missouri Gov. Mike Kehoe signed House Bill 594, which will exclude both short- and long-term capital gains from Missouri individual income tax and, in certain circumstances, corporate income tax....more
The One Big Beautiful Bill Act, signed into law on July 4, 2025, by President Donald Trump, delivers sweeping changes to the U.S. tax code, with major implications for businesses — particularly regarding solar and wind tax...more
On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), which included revisions to Section[1] 1202 for “qualified small business stock” (QSBS) unchanged from those initially introduced in the...more
On July 4, 2025, the legislation commonly known as “The One Big Beautiful Bill Act” (the “BBBA”) was enacted. The BBBA makes permanent, extends and, in certain cases, modifies, a number of provisions from the 2017 Tax Cuts...more
1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more
Income received by a multistate business is either “business income” or “non-business income.” Although this labeling appears innocuous, the distinction between these two categories of income matters greatly to taxpayers and...more
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
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
A recent court ruling in the Shalam Packaging Products Group case addressed claims made by the Netanya tax assessor. The assessor argued the group executed a restructuring solely to reduce its tax liabilities by offsetting...more
Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more
What are the tax accounting rules for hedges? Whether or not a qualified tax hedge is properly identified, it must be tax accounted for under a method that clearly reflects income. The timing of gains and losses on hedges...more
When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more
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