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Exclusions Internal Revenue Code (IRC) Tax Planning

Holland & Knight LLP

A Look at Transfers of Section 1202 Qualified Small Business Stock

Holland & Knight LLP on

Section 1202 of the Internal Revenue Code provides that noncorporate taxpayers may exclude certain gains on the disposition of Qualified Small Business Stock (QSBS) held longer than the minimum required holding period. One...more

Frost Brown Todd

One Big Beautiful Bill Act Enacts a Permanent Increase in the Estate and Gift Tax Lifetime Exclusion Amount for 2025 and Later...

Frost Brown Todd on

On July 3, 2025, and by a vote of 218 to 214, the U.S. House of Representative passed the Senate’s amended version of H.R. 1 (also known as the “One Big Beautiful Bill Act” or OBBBA 2025), which is the tax-and-budget...more

Jaburg Wilk

Exclusions, Exemptions, Estate Tax – What to Know in 2025

Jaburg Wilk on

As we enter 2025, it’s important to stay informed about the current federal estate and gift tax laws, including annual exclusion limits and significant changes anticipated by the end of this year. Annual Exclusion Amount- ...more

DarrowEverett LLP

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

DarrowEverett LLP on

In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

Kohrman Jackson & Krantz LLP

Limited in Name but Not in Tax? U.S. Tax Court Increases Tax Liability for Limited Partners

Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more

Bilzin Sumberg

Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

Bilzin Sumberg on

The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

Woods Rogers

‘Tis the Season (For Charitable Giving)

Woods Rogers on

The year-end is approaching, but you still have time to work on your 2022 tax planning. Consider giving to your favorite charity to make this holiday season merry. Planned charitable giving provides you a way to maximize...more

Foster Garvey PC

The Oregon Department of Revenue Held Its CAT Call as Scheduled – The Business and Tax Community Were Represented

Foster Garvey PC on

As we reported last week, the Oregon Department of Revenue (“DOR”) scheduled a public hearing on June 23, 2020 to discuss the second set of temporary administrative rules relative to the Oregon Corporate Activity Tax (the...more

McDermott Will & Emery

Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base

McDermott Will & Emery on

On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more

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