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Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment returns, while offsetting...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
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
At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...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
After months of intense negotiations, on July 4, 2025, the One Big Beautiful Bill (OBBB) was signed into law making various changes to the tax code that impacts estate, gift and income tax planning. Increased Estate, Gift...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
The recently signed One Big Beautiful Bill Act (OBBBA) implements significant changes under Section 1202 of the Internal Revenue Code of 1986 (Code), applicable to qualified small business stock (QSBS) issued on or after July...more
President Trump signed into law the One Big Beautiful Bill Act (the “Act”) on July 4, 2025 (the “Signing Date”). Among the Act’s significant tax extensions and changes to tax law are several taxpayer-favorable revisions to...more
The One Big Beautiful Bill Act (H.R. 1, 119th Cong § 70431 (2025)) (“Act”) was signed into law by President Trump on July 4, 2025, after narrowly passing the House on July 3, 2025....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, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law, which had narrowly passed through the United States Congress. The OBBBA makes permanent certain tax provisions that were due to expire...more
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
Issuing qualified small business stock (“QSBS”) is a valuable tool that can provide significant tax savings to searchers and independent sponsors alike upon the eventual sale of one or more of their portfolio companies....more
Maryland Governor Wes Moore is expected to sign (if he has not by the date of this publication) House Bill 0350 in the coming weeks. The final version of the bill includes several major tax increases to address budget...more
As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...more
The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more
In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more
Buying or selling a business is an exciting experience, and potentially lucrative opportunity for all parties. Most often, during the letter of intent / early negotiations phase, a “deal” is struck based primarily on economic...more
On March 20, 2025, New Jersey lawmakers advanced a measure that would bring the New Jersey Gross Income Tax into closer conformity with federal law regarding the income tax treatment of “qualified small business stock,” or...more
The “qualified small business stock” (QSBS) tax exemption under Section 1202 allows non-corporate founders and investors in certain emerging growth companies to potentially exclude up to 100 percent of the U.S. federal...more
The new UK fund vehicle Reserved Investor Fund (RIF) is available beginning today, 19 March 2025. The RIF is available for all investment strategies, but what might make it an appealing option, particularly certain tax...more
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
On February 6, 2025, the Trump Administration announced various tax and budgetary priorities discussed further here, including closing the “carried interest loophole.” On the same day, Democrats in the House and Senate...more