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PODCAST: Williams Mullen's Raising Capital 101: A Securities Podcast - What are the Different Ways Securities Can Be Offered and Sold? (Part 1)
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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
What is tax-loss harvesting? “Tax-loss harvesting,” in its simplest form, is the sale of a capital asset at a loss to “mop up” tax that would otherwise be due on capital gain from the sale of another capital asset. Capital...more
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
In uncertain economic times, many individuals are concerned about the value of their investments, and for good reason. When the stock market dips or real estate prices fall, the effect isn’t just felt in personal investment...more
Anticipated to be finalized and adopted in July 2025, the new tax reforms for Kazakhstan would go into effect in January 2026. This LawFlash summarizes the taxation of income from capital gains when selling shares and...more
Our Employee Benefits & Executive Compensation Group discusses how employers can use voluntary employees’ beneficiary association (VEBA) asset reallocations while meeting ERISA fiduciary obligations....more
An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more
On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more
As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more
On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more
A 1031 UPREIT (Umbrella Partnership Real Estate Investment Trust) transaction allows real estate investors to exchange property on a tax-deferred basis under IRS Section 1031 while gaining diversification and liquidity by...more
On May 12, 2025, the House Committee on Ways and Means Chairman Jason Smith (R-MO) released an amended 389-page bill, entitled “The One, Big, Beautiful Bill,” and the staff of the Joint Committee on Taxation released a...more
The replacement of the UK’s paper-based stamp duty (SD), and its electronic cousin stamp duty reserve tax (SDRT), with a unified and modernised single tax on securities transactions re-emerged this week as a Government...more
The South Carolina Court of Appeals determined that Duke Energy Corporation (“Duke”) was entitled to claim nearly $25 million in investment tax credits on its 1996 to 2014 South Carolina income tax returns, as the investment...more
Dans une décision du 12 mars 2025, le Conseil d'Etat confirme que si l'inscription initiale de titres en titres de participation constitue une erreur délibérée, la société ne peut bénéficier des effets d'une rectification de...more
A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more
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
In connection with the first Trump administration’s tax bill known as the Tax Cuts and Jobs Act (“Jobs Act”), a cap on state and local tax deductions was instituted at $10,000 (“SALT Cap”) for tax years 2018 through 2025. The...more
As cryptocurrencies like Bitcoin surge to unprecedented values—crossing the $100,000 mark at the time of this writing—both seasoned investors and newcomers are pouring billions into this thriving asset class. The U.S....more
Litigation attorneys have had the ability to defer contingency fees since 1994. You are hard pressed to find another profession that has this tax advantage. Hedge fund managers have been running and winning the “Death Race”...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
This inaugural issue of ArentFox Schiff’s publication on international mining, energy, and infrastructure disputes aims to provide insights and practical information to general counsels and senior executives of companies...more
Dans une décision mentionnée aux tables du Recueil Lebon, le Conseil d'Etat affirme la légalité de la doctrine administrative du 3 avril 2024, selon laquelle doivent être prises en compte, pour le calcul de la plus-value...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
In recent years, the utilization of qualified small business stock (“QSBS”) has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section...more