News & Analysis as of

Internal Revenue Code (IRC) Tax Planning Tax Benefits

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

Foster Garvey PC

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

Foster Garvey PC on

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

Lowenstein Sandler LLP on

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

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

Jones Day

Qualified Small Business Stock Benefits Expanded in New Tax Bill

Jones Day on

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

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

Bodman

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

Bodman on

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

Greenberg Glusker LLP on

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

Patterson Belknap Webb & Tyler LLP

Changes to QSBS Rules

As if QSBS wasn’t good enough already, the “Big Beautiful Bill” signed into law by President Trump on July 4, 2025 enacts significant, founder-friendly changes to Section 1202 of the Internal Revenue Code, which substantially...more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

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Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Holland & Knight LLP

Independent Sponsors: Section 1202 Qualified Small Business Stock

Holland & Knight LLP on

The tax benefits conveyed by Section 1202 of the Internal Revenue Code to owners of qualified small business stock (QSBS) have been available to small business owners in some form since Section 1202 was first enacted in 1993....more

Greenberg Glusker LLP

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

Greenberg Glusker LLP on

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

Offit Kurman

Equal Shares, Unequal Outcomes: Estate Planning Strategies for Parents and their Qualified Retirement Accounts

Offit Kurman on

Typically, a parent wishes to treat their children equally in their estate plan and presumes they will achieve this goal by dividing all their assets into equal shares upon their death. Accordingly, they will designate their...more

Hinckley Allen

Converting an LLC to an S Corporation: A Mistake Waiting to Happen

Hinckley Allen on

Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more

Gray Reed

IRS Takes Warning Shot at Section 643(b) Trust Arrangements

Gray Reed on

For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.”  On August 9, 2023, IRS Chief...more

McDermott Will & Schulte

The Working Capital Safe Harbor

McDermott Will & Schulte on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Bilzin Sumberg

What Makes a Trust a "Foreign" Trust?

Bilzin Sumberg on

In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal...more

Foster Garvey PC

Opportunity Zone Funds – Part III: Lots of Questions But Few Answers

Foster Garvey PC on

There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more

Holland & Knight LLP

Seven Tips for Tribal Governments to Reduce Tribal Member Taxes in 2019

Holland & Knight LLP on

• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VIII: Charitable and Tax-Exempt Organizations / Estate and Gift Taxes

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Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Recent Court of Appeals Decision Provides Hope for Taxpayers Fighting for Congressionally Sanctioned Tax Benefits"

For the second time in just over a year, the U.S. Court of Appeals for the Sixth Circuit reversed the United States Tax Court and affirmed the right of a taxpayer to structure its affairs in a manner that takes into account...more

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