News & Analysis as of

Internal Revenue Code (IRC) Tax Planning Investors

Arnall Golden Gregory LLP

QSBS Revamped: Important Changes to the Qualified Small Business Stock Exclusion for Founders and Investors

The One Big Beautiful Bill Act (“OBBBA”), signed into law on July 4, 2025, introduced a number of significant amendments to the Internal Revenue Code. Among the OBBBA’s most notable changes are the revisions to Section 1202...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

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

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

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

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

Jones Day

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

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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

Bodman

One Big Beautiful Bill Act Reinforces and Enhances Qualified Small Business Stock Tax Savings – A Benefit for Prospective Startup...

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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

Greenberg Glusker LLP

The Tax Joys of Opportunity Zones

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The 2025 tax bill extends and expands the tax benefits to taxpayers that have capital gain and invest an amount equal to the realized gain to acquire an interest in a “Qualified Opportunity Fund,” which in turn invests in...more

Holland & Knight LLP

One Big Beautiful Bill Act Increases Tax Benefits for Qualified Small Business Stock

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President Donald Trump on July 4, 2025, signed into law H.R. 1, commonly referred to as the One Big Beautiful Bill Act (OBBB). (For a detailed analysis of the bill, see Holland & Knight's previous alert, "Trump Signs the One...more

McDermott Will & Schulte

One Big Beautiful Bill Act brings major changes to Section 1202 capital gains exclusion

The recently passed One Big Beautiful Bill Act (OBBBA) makes significant and immediate changes to the tax rules surrounding qualified small business stock (QSBS) under Section 1202 of the Internal Revenue Code. These rules...more

Cozen O'Connor

Expansion of QSBS Benefits Under the One Big Beautiful Bill

Cozen O'Connor on

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

Gould + Ratner LLP

OBBB Act Brings Significant Changes to Section 1202 QSBS Gain Exclusion

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On July 4, President Donald Trump signed the One Big Beautiful Bill Act (“OBBB”) into law. Among many changes, the OBBB included an expansion of the qualified small business stock (“QSBS”) gain exclusion under Section 1202 of...more

Vinson & Elkins LLP

Update: OBBBA Tax Provisions Impacting REITs and Foreign Investors

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On July 1, 2025, a little over two weeks after the Senate Finance Committee released its draft tax title (the “Initial Senate Draft”), the U.S. Senate secured sufficient votes to advance its version of the “One Big Beautiful...more

Wilson Sonsini Goodrich & Rosati

Understanding Section 1202: The Qualified Small Business Stock Exemption

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

Kohrman Jackson & Krantz LLP

Combining Membership Interest Purchase Agreements & 1031 Exchanges to Maximize Tax Efficiency in Real Estate Deals

The intersection of real estate transactions and tax strategy has long been a focal point for investors seeking to optimize returns while minimizing liabilities. Two powerful tools in this arena – the Membership Interest...more

DLA Piper

House Committee on Ways and Means Proposed Tax Bill: Key Takeaways

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On May 9, 2025, House Committee on Ways and Means Chairman Jason Smith (R-MO) released a proposed 28-page tax bill, which is scheduled for markup by the House Committee on Ways and Means on May 13, 2025. Below, we highlight...more

Blank Rome LLP

Cannabis ESOPs Provide Solutions for Operators

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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

Wilson Sonsini Goodrich & Rosati

Understanding Section 1202: The Qualified Small Business Stock Exemption

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

Gerald Nowotny - Law Office of Gerald R....

To Be or Not to Be Contemplating the Meaning of Life Through Private Placement Life Insurance

The focus of this article illustrates why private placement life insurance (“PPLI”) is the best asset to utilize in the “Buy, Borrow and Die” strategy for high net worth investors including billionaires. After this article,...more

DarrowEverett LLP

Unlocking Tax-Free Gains: The Power of QSBS in Mergers & Acquisitions

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Internal Revenue Code (IRC) Section 1202 offers a significant tax incentive for investors in qualified small business stock (QSBS). This provision allows eligible shareholders to exclude up to 100% of capital gains realized...more

Greenberg Glusker LLP

[Webinar] Maximizing Tax Benefits with Qualified Small Business Stock (QSBS): Key Insights and Strategies - March 27th, 10:00 am -...

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This presentation will cover essential aspects of QSBS eligibility, the tax benefits available under Section 1202, and practical approaches for maximizing exclusions on capital gains. This session will include recent updates,...more

Morrison & Foerster LLP

Frequently Asked Questions about UPREITs and OP Unit Transactions

A common structure for equity REITs, the UPREIT model allows a REIT to hold and operate its assets through a single operating partnership. This structure provides tax advantages and liquidity opportunities for property...more

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