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Internal Revenue Code (IRC) Tax Planning

Jackson Walker

The One Big Beautiful Bill’s New Qualified Opportunity Zones

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Under the One Big Beautiful Bill Act (the “OBBBA”), the qualified opportunity zone (QOZ) program will no longer sunset on December 31, 2026, as was set to be the case prior to the act’s passage. Instead, the OBBBA makes this...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part VII – The Rules Relating to the Deductibility of Individual...

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In this seventh installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that impact the deductibility of individual charitable gifts under Code Section 170....more

Mintz - Tax Viewpoints

New Electronic Filing Option for Section 83(b) Elections

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On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

Bilzin Sumberg

Section 1202 – Enhanced Opportunities in Increased Exclusions and Caps

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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

Hughes Hubbard & Reed LLP

Expansion of Qualified Small Business Stock Tax Benefits

On July 4, President Donald Trump signed a budget reconciliation bill entitled the “One Big, Beautiful Bill Act” (the Act). The Act extends the tax cuts that were enacted as part of the Tax Cuts and Jobs Act of 2017, adds a...more

Farrell Fritz, P.C.

Expanded Qualified Small Business Stock Rules

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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

Paul Hastings LLP

One Big Beautiful Bill Act — A Private Equity Perspective

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On July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA). This alert summarizes the key changes under the OBBBA relevant to private equity sponsors and their investors, as well as some of the...more

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

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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

Morrison & Foerster LLP

Say Goodbye to Paper Cuts: Section 83(b) Elections May Now Be Filed Online

In late 2024, the Internal Revenue Service (IRS) introduced Form 15620 to provide a standardized mechanism for taxpayers to make elections under Section 83(b) of the Internal Revenue Code (the “Code”). More recently in 2025,...more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Blank Rome LLP

One Big Beautiful Bill Act: Key Business, International, and Employment Tax Provisions

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The federal government enacted the One Big Beautiful Bill Act (the “Act”) on July 4, 2025. The Act extends and makes permanent certain tax provisions introduced in the Tax Cuts and Jobs Act (the “TCJA”) that were scheduled to...more

Allen Matkins

Bonus Depreciation Is Back! And Other Big Beautiful Taxes

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On Friday, July 4, 2025, President Trump signed into law the Reconciliation Bill commonly known as the One Big Beautiful Bill Act (OBBBA). Broadly speaking, the OBBBA extends and makes permanent many provisions enacted by the...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part V – Qualified Small Business Stock Exclusion / Code Section...

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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

Lowenstein Sandler LLP

One Big Beautiful Bill and Opportunities To Avoid or Defer Tax on Gains

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On July 4, 2025, President Donald Trump signed into law the One Big Beautiful Bill Act (H.R.1) (OBBBA). This alert focuses on OBBBA changes regarding qualified small business stock (QSBS) and qualified opportunity zone (QOZ)...more

BCLP

Qualified Small Business Stock Benefits Expanded Under the One Big Beautiful Bill Act

BCLP on

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. Among the many changes, the Act expands the favorable tax treatment for Qualified Small Business Stock (“QSBS”) under Section 1202...more

ArentFox Schiff

QSBS Gets Supercharged Under New Tax Law

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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

Holland & Knight LLP

A Look at Transfers of Section 1202 Qualified Small Business Stock

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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

McCarter & English, LLP

One Big Beautiful Bill Act Tax Law Updates–Private Educational Institutions and Nonprofits

On July 4, 2025, President Trump signed into law legislation commonly referred to as the “One Big Beautiful Bill Act” (OBBBA), which includes provisions that specifically affect private primary, secondary, and post-secondary...more

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for the Real Estate Industry

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On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...more

Jones Day

Qualified Small Business Stock Benefits Expanded in New Tax Bill

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The One Big Beautiful Bill Act expands the qualified small business stock benefits available to founders and investors....more

Goodwin

Online Filing of Section 83(b) Elections Is Here!

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Last year, the US Internal Revenue Service (IRS) released Form 15620 for taxpayers to make elections under section 83(b) of the Internal Revenue Code, an important part of US tax planning for founders, employees, board...more

Jones Day

The One Big Beautiful Bill Becomes Law: Key Real Estate Tax Changes

Jones Day on

Signed into law on July 4, 2025, the One Big Beautiful Bill Act (the "Act") permanently extends and modifies several cornerstone provisions of the Tax Cuts and Jobs Act of 2017, restores key business incentives, and makes...more

Morrison & Foerster LLP

One Big Beautiful Bill Expands Qualified Small Business Stock Exemptions

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

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for Investment Funds and Sponsors

Troutman Pepper Locke on

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more

Husch Blackwell LLP

Estate Planning and Other Tax Strategies under the One Big Beautiful Bill Act

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President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law on July 4, 2025. The OBBBA represents a significant overhaul of the U.S. tax system, making permanent many provisions of the 2017 Tax Cuts and Jobs...more

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