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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
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
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
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
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
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
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
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
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
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
The Cohan Rule: Tax Deductions with Incomplete Records - The “Cohan rule” is derived from the Second Circuit’s 1930 decision, Cohan v. Commissioner, which allowed the taxpayer to approximate travel and entertainment...more
Living the Dream- “How was your weekend?” Thank you for asking. Awful. “Why?” you ask. (Humor me. Pretend you’re interested.) I’ll tell you. One word, with 535 syllables: Congress. When the reconciliation budget...more
This blog summarizes some of the tax proposals of President-elect Joe Biden and other prominent Democrats. Biden’s Proposals - Increased Individual Tax Rate - Biden would increase the top marginal income tax rate...more
This past November, we outlined selected tax law changes that President-elect Joe Biden has proposed, both in speaking engagements and on his campaign website, some or all of which could be enacted in 2021 or future years. ...more
With Biden as the projected President-Elect (subject to pending federal litigation and the Electoral College vote), tax planning for late 2020, 2021, and beyond is top of mind for many businesses and individuals....more
Wither The Senate? I was reviewing a reorganization plan Saturday morning – coffee and chocolate chip cookies within easy reach – when an email crossed my screen with the subject line that each of NBC, CNN, ABC and the...more
We’re roughly a month from Election Day, and I think it’s safe to say many Americans have strong opinions about who should be our President for the next four years. I also think it’s safe to say taxes are not the top...more
Under current (post-2017) federal income tax law, long-term capital gain allocated to or realized by a non-corporate recipient of a promote or other performance-based allocation (a "Carried Interest") in the investment...more
On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more
On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...more