News & Analysis as of

High Net-Worth Tax Reform

Lowenstein Sandler LLP

One Big Beautiful Bill and Three Key Planning Notes

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Last week, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA). At nearly 900 pages in length, OBBBA’s size lives up to its name by enacting sweeping changes to estate and gift taxes, income taxes,...more

McDermott Will & Emery

Key One Big Beautiful Bill Act implications for family offices and high-net-worth investors

McDermott Will & Emery on

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA), the most significant US tax overhaul since the 2017 Tax Cuts and Jobs Act (TCJA). The OBBBA includes critical changes impacting family offices,...more

Cole Schotz

Salt Provisions In The One Big Beautiful Bill Act: A Mirage Rather Than A Panacea Of Relief For High-Income Earners

Cole Schotz on

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law ushering in sweeping federal tax changes. The legislation notably expands the Qualified Business Income (QBI) deduction for professionals...more

Venable LLP

SALT Alert: Senate Unveils Updated OBBBA SALT Cap Proposal

Venable LLP on

On June 28, 2025, Senate Republicans released their updated version of the One Big Beautiful Bill Act (OBBBA), moving closer to finalizing their sweeping tax reform package ahead of a self-imposed July 4 deadline. A key...more

Ballard Spahr LLP

WA Estate and Capital Gains Tax Changes Under SB 5813

Ballard Spahr LLP on

Facing a projected budget deficit of $12 to $16 billion, Governor Bob Ferguson signed several bills into law this week which will significantly increase taxes in Washington State. An overview of the increases to Business and...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Hinshaw & Culbertson LLP

Use It or Lose It: Federal Gift and Estate Tax Exemption Set to Sunset at the End of 2025

The Tax Cuts and Jobs Act (TCJA) of 2017 nearly doubled the federal lifetime gift and estate tax exemption. In 2024, this act currently allows individuals to transfer up to $13.61 million per person and $27.22 million per...more

Mayer Brown

Measure ULA Update: Reported Revenue, Applicability to Foreclosures and Legal Challenges

Mayer Brown on

In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more

Woods Rogers

IRS Announces New Initiatives to Restore Fairness to Tax System

Woods Rogers on

On September 8, 2023, the IRS announced the start of a “sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promotors...more

Polsinelli

IRS Says: New Goal is to Restore Fairness by Using Tax Dollars to Audit More Millionaires, Partnerships and Large Corporations

Polsinelli on

Following our initial reaction to the Internal Revenue Service's strategic operating plan to spend $80B in funding allocated from the Inflation Reduction Act, Polsinelli’s Tax attorneys continue to monitor the IRS’ compliance...more

Cadwalader, Wickersham & Taft LLP

Potential Constitutional Challenge: Biden Budget Proposes Mark-to-Market for High-Net-Worth Individuals

In President Biden’s State of the Union address, he called on all Americans to pay their “fair share.” The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals contains several...more

Brownstein Hyatt Farber Schreck

White House Releases FY 2024 Budget Request

Earlier today, the White House released its fiscal year (FY) 2024 budget request to Congress. Overall, it proposes $6.9 trillion in total spending, including a proposed $880 billion for defense and approximately $992 billion...more

Cadwalader, Wickersham & Taft LLP

The States Come Marching In: Investors Ignore State Wealth Taxes at Their Peril

As President Biden reminded taxpayers in his recent State of the Union address, the federal government continues to pursue new taxes on high-net-worth individuals. While such efforts have foundered in Congress, causing many...more

Allen Matkins

Attention Property Owners: Los Angeles and Santa Monica Approve ‘Mansion Tax’ Ballot Measures, Increasing Transfer Taxes on Sales...

Allen Matkins on

Residents of Los Angeles have approved Measure ULA, a ballot measure widely known as the “Mansion Tax,” which increases transfer tax rates on real estate sales valued at $5 million or more. Prior to Measure ULA, real estate...more

Goulston & Storrs PC

Taxachusetts Redux? The New Massachusetts Millionaires Tax

Goulston & Storrs PC on

On November 8, 2022, Massachusetts voters elected to adopt Question 1, the so-called Fair Share Amendment or Massachusetts Millionaires Tax, through a ballot referendum. The referendum amends the Massachusetts state...more

Cadwalader, Wickersham & Taft LLP

A Pocket Guide to the 2023 Budget Proposals

On March 28, 2022, the Biden Administration released its budget proposal for Fiscal Year 2023 (the Budget). We summarize below the tax aspects of the Budget of particular interests to U.S. corporate taxpayers, financial...more

Goulston & Storrs PC

Biden’s FY2023 Budget: Key Real Estate & Corporate Tax Proposals

Goulston & Storrs PC on

On March 28, 2022, President Biden released his FY2023 budget (the “FY2023 Budget”), and the U.S. Treasury released the so-called “Green Book,” which provides details related to the revenue provisions in the FY2023 Budget....more

Proskauer - Tax Talks

The Biden Administration Proposes Mark-to-Market Minimum Tax on Individuals With More than $100 Million in Assets

Proskauer - Tax Talks on

Summary and Background. On March 28, 2022, the Biden Administration proposed a 20% minimum tax on individuals who have more than $100 million in assets.  The minimum tax would be based on all economic income (which the...more

Freeman Law

Notable Tax Takeaways from President Biden’s Budget

Freeman Law on

On March 28, 2022, President Joe Biden released his FY 2023 Budget of the U.S. Government (the “Budget”). In a statement regarding the Budget, President Biden stated the following...more

Miller Nash LLP

Today in Tax: The Billionaire Minimum Income Tax and Cryptocurrency Tax Provisions in Biden’s 2023 Budget Proposal

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. The Billionaire Minimum Income Tax in Biden’s 2023 Budget Proposal - Biden’s proposed “top-up” tax on wealthy individuals would ensure...more

Polsinelli

The Proposed Build Back Better Act Moves Forward After the House Passes a Revised Version of the Bill

Polsinelli on

Overview - Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more

Miles & Stockbridge P.C.

Tax Alert: The Implications of the Build Back Better Act

Miles & Stockbridge P.C. on

Updates and negotiations for President Biden’s tax plan continue to filter through Congress. The House Ways and Means Committee recently passed the Build Back Better Act (the “Act”), and it is now on its way for the Senate’s...more

Cadwalader, Wickersham & Taft LLP

House Passes Build Back Better Act

Here's a summary of the tax provisions in the Build Back Better Act, as passed by the House. I. Introduction - On November 19, 2021, the House of Representatives passed the Build Back Better Act (the BBBA)....more

Davies Ward Phillips & Vineberg LLP

Revised U.S. Tax Proposals Will Affect Foreign Investment

The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). ...more

Cadwalader, Wickersham & Taft LLP

Wyden’s Billionaires Tax

On October 27, 2021, Senate Finance Committee Chair Ron Wyden (D-Ore.) released draft legislation that would, if enacted, tax the roughly 700 wealthiest Americans on a modified mark-to-market basis by requiring them to pay...more

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