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Capital Gains Proposed Legislation

Proskauer Rose LLP

UK Tax Round Up - July 2025

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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

Opportune LLP

Tax Implications of the One Big Beautiful Bill Act in the U.S. Energy Industry

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On May 22, 2025, the House Budget Committee approved the President Trump-supported tax legislation called the One Big Beautiful Bill Act (the “OBBBA”). As the OBBBA works its way through Congress with the Senate targeting a...more

Seyfarth Shaw LLP

A New Chapter for Opportunity Zones

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The Opportunity Zone program (the “OZ Incentive Program”), launched under the 2017 Tax Cuts and Jobs Act, was designed to spur economic development in distressed communities by offering tax incentives to investors. As part of...more

Mintz - Tax Viewpoints

QSBS Benefits Expanded Under Senate Finance Proposal

Mintz - Tax Viewpoints on

On June 16, 2025, the Senate Finance Committee released its own version of proposed legislation following the House’s passage of the “One Big Beautiful Bill Act” (H.R. 1). While the House bill did not introduce any changes to...more

Cadwalader, Wickersham & Taft LLP

Congress Targets Partnership Disguised Sales and Services

Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more

WilmerHale

Section 1202 “Qualified Small Business Stock” Tax Benefits May Be Significantly Expanded as Part of Tax Package

WilmerHale on

On June 16, 2025, the Senate Finance Committee released its draft legislative text (the Senate Proposal) following the prior passage of the One Big Beautiful Bill Act by the House of Representatives (the House Bill). ...more

Wilson Sonsini Goodrich & Rosati

Senate Finance Committee Proposes Significant Expansion of the Qualified Small Business Stock (QSBS) Tax Exemption

On June 16, 2025, the Senate Finance Committee released draft text of the tax provisions in the Senate’s version of H.R. 1 (commonly referred to as the “One Big Beautiful Bill” (the SFC Bill)). Notably, the SFC Bill would...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

Troutman Pepper Locke on

On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

Miles & Stockbridge P.C.

For Whom the Tax Tolls: Maryland’s Budget Bill and Its Fiscal Effects

Maryland Gov. Wes Moore recently signed the $67 billion state budget for 2026 (HB 352) that will make significant changes to the state’s tax system. Among other changes, the budget bill notably establishes a new tax on IT...more

Cadwalader, Wickersham & Taft LLP

Carried Interest Survives Budget Bill … for Now

On May 15, 2025, the House released the draft FY 2025 budget bill. As currently drafted, the budget bill does not limit or otherwise change the tax treatment of carried interest.  Following the release of the budget bill,...more

Barnea Jaffa Lande & Co.

Knesset Committee Approves Bill Easing Tax Relief in Restructuring

The Knesset Finance Committee approved a draft bill for second and third readings to ease the conditions for tax relief during corporate restructuring. The bill was first published in the initial draft bill within the tax...more

Stikeman Elliott LLP

Prorogation of Parliament and the Proposed Capital Gains Inclusion Rate Increase

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On January 6, 2025, Prime Minister Justin Trudeau announced his resignation as prime minister and the prorogation of Parliament until March 24, 2025. At the federal level, prorogation is an act by the Governor General,...more

Davies Ward Phillips & Vineberg LLP

Government of Canada Releases Package of Proposed Domestic and International Tax Legislation

The Department of Finance (Finance) released draft tax legislation for public consultation on August 4, 2023, with a stated focus on promoting tax fairness and a clean economy. The most significant item released is the...more

Cadwalader, Wickersham & Taft LLP

Mini-Me Crypto Tax Legislation

Bipartisan crypto legislation was introduced by Senators Pat Toomey (R-PA) and Kyrsten Sinema (D-AZ) on July 26, 2022. If enacted, the Virtual Currency Tax Fairness Act would exclude from gross income gain on certain de...more

Morrison & Foerster LLP

Proposed “Inflation Reduction Act” Could Significantly Curtail Carried Interest Tax Benefits

On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin announced their agreement on proposed legislation (the “Inflation Reduction Act of 2022” or “Act”) that is expected to be considered by the Senate...more

Paul Hastings LLP

Proposed Legislation Threatens to Upend Carried Interest Rules

Paul Hastings LLP on

As widely reported, on July 27, 2022 Democratic Majority Leader Senator Chuck Schumer and Senator Joe Manchin (D-W.Va) agreed to a reconciliation bill package titled the Inflation Reduction Act of 2022. The bill contains...more

McDermott Will & Emery

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Holland & Knight LLP

Congress Looks to Update Opportunity Zone Program with Bipartisan, Bicameral Legislation

Holland & Knight LLP on

A group of bipartisan senators and representatives on April 7, 2022, introduced The Opportunity Zones Transparency, Extension, and Improvement Act (the Act). If enacted later this year, this legislation would be the first...more

BCLP

German Property Investments: German Trade Tax Deduction For Property Companies

BCLP on

Summary - ..Based upon a change of law as from 2021 German property companies are allowed to deliver electricity and earn income from contractual relationships with their tenants within certain thresholds without...more

Lowndes

Renewed Opportunities: Recent Bipartisan Proposal Seeks to Refine Opportunity Zone Development and Tax Incentives

Lowndes on

In 2017, the Tax Cuts and Jobs Acts (TCJA) created a capital gains investing program aimed at revitalizing impoverished neighborhoods in the United States, known as “Qualified Opportunity Zones.” The purpose of this program...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed House Tax Plan, Now Being Updated by the Senate, Is in Flux: Year-End Update

Despite Senator Joe Manchin’s (D-West Virginia) recent announcement that he would not support a comprehensive version of Build Back Better, we expect Congress will advance some parts of the legislation early in 2022. The...more

Cadwalader, Wickersham & Taft LLP

Keep Your Eyes on Mark-to-Market

We report elsewhere in this issue on Senate Finance Committee Chair Ron Wyden's (D-Ore.) proposed mark-to-market tax on billionaires. On August 5, 2021, Wyden also introduced the Modernization of Derivatives Tax Act of 2021...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

Bowditch & Dewey on

In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

Verrill

House Democrats Propose Estate and Gift Tax Law Changes: Important Estate Planning Implications

Verrill on

What you need to know: On September 13, 2021, the House Ways and Means Committee released its proposed tax plan to fund President Biden’s $3.5 trillion “Build Back Better” social and economic spending package. If enacted as...more

WilmerHale

In Case You Missed It: Launch Links - May 2021 #2

WilmerHale on

Some interesting links we found across the web this week: Startup Employees Should Pay Attention to Biden’s Capital Gains Tax Plans  The Biden Administration proposed significant changes to the capital gains tax....more

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