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The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, establishes new phased-in benefits for Qualified Small Business Stock (QSBS) held for at least three years. ...more
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
As part of the newly enacted One Big Beautiful Bill Act (the OBBBA),[1] Congress adopted the first substantive amendments to Section 1202[2]–which prescribes the qualified small business stock (QSBS) rules–in over a decade...more
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
On July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), a sweeping 870-page piece of legislation that introduces significant changes across various areas of federal policy. While full...more
The energy storage industry has continued to progress over the course of 2024 and into 2025, buoyed in significant part by the federal income tax benefits in the form of tax credits enacted under the Inflation Reduction Act...more
Ohio has emerged as a key player in the Midwest’s economic development, particularly in the realms of technology and infrastructure. A standout feature of the state’s growth is the rise of data centers, which have become...more
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
Private foundations providing support, resources, and advocacy for individuals and families affected by rare diseases have played an important role for more than 30 years in the advancement of treatments for rare diseases....more
On February 6, 2025, Democratic Senators and Representatives proposed the Carried Interest Fairness Act, which would treat carried interest as ordinary income. Additionally, on the same day President Trump met with...more
Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...more
The “qualified small business stock” (QSBS) tax exemption under Section 1202 of the Internal Revenue Code allows non-corporate founders and investors in certain emerging growth companies organized as corporations to...more
The Inflation Reduction Act of 2022 (the “IRA”) now allows firms to develop and sell clean energy tax credits. In our last update, we discussed how the emerging market for tax insurance may provide comfort to prospective...more
Under the IRA, select renewable energy credits are transferrable, including to individuals and pass-through entities. The transferees of these credits are subject to the passive activity rules of Section 469 of the...more
Real estate developers have long had ample reasons to take on projects involving historic buildings, courtesy of Section 47 of the Internal Revenue Code of 1986. As amended, Section 47 (the “Code”) provides for a...more
The Treasury Department and the Internal Revenue Service (IRS) recently released long-awaited proposed regulations regarding the carbon capture and sequestration tax credit provided under Section 45Q of the Internal Revenue...more