From Legislation to Implementation: Understanding Section 1202 Changes — Troutman Pepper Locke Podcast
Crypto's Capital Markets Revolution: Insights From GSR's Josh Riezman — The Crypto Exchange Podcast
A New Brand of Uncertainty? — PE Pathways Podcast
JONES DAY TALKS®: Real Assets Roundup: A New Look at Real Estate, Energy, and Infrastructure - Episode 1
Treating Compliance Like an Asset
Daily Compliance News: June 17, 2025, The JBS Goes Public Edition
(Podcast) The Briefing: Who Owns Jack Nicklaus? Lessons for The Creator Economy From a Brand Battle
The Briefing: Who Owns Jack Nicklaus? Lessons for The Creator Economy From a Brand Battle
Foreign Correspondent Podcast | The America First Investment Policy and What it Means for Investors
LathamTECH in Focus: How Should Crypto Companies Be Thinking About New Laws?
Podcast - Navigating the New Landscape of Private Equity in Healthcare
The Preferred Return Podcast | Balancing Act: Strategies for GPs and LPs in Today's Market
PODCAST: Williams Mullen's Raising Capital 101: A Securities Podcast - What are the Different Ways Securities Can Be Offered and Sold? (Part 1)
2025 Oil Market Outlook: What OPEC, U.S. Shale, and Natural Gas Trends Mean for the Year Ahead
2025 Perspectives in Private Equity: AI & Technology
2025 Perspectives in Private Equity: Sports
Foreign Correspondent: An FDI Podcast | Mapping the National Security Landscape for Investors
Scaling Sustainable Fuel for the Future | Insights with Niels Jensen
AdvisorEsq Podcast Series - Episode 10 - Planning Ahead: The Valuation Equation
[Podcast] Private Market Talks: Unlocking the Potential of Alternative Markets with HighVista Strategies’ Raphi Schorr
Life sciences companies (particularly early stage companies) may be attracted to an LLC holding company structure as an alternative to a typical C corporation structure to maximize both the purchase price paid by a future...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
Issuing qualified small business stock (“QSBS”) is a valuable tool that can provide significant tax savings to searchers and independent sponsors alike upon the eventual sale of one or more of their portfolio companies....more
Corporate Partner, Eric Perlmutter-Gumbiner, shared his expertise on latest developments and trends in the business of beauty, fashion, and consumer goods with Los Angeles Times in their Beauty, Fashion & Consumer Goods...more
On April 24, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations on the definition of “domestically controlled” real estate investment trusts (“REITs”)...more
The United States Department of Treasury issued final regulations (Final Regulations) that arguably change the test (DC Test) for determining whether a REIT is a domestically controlled qualified investment entity (DC-REIT)....more
Decisions- It is often the case that the optimal form of legal entity through which a business should operate, at least for income tax purposes, will depend in part upon the stage of its life cycle in which the business...more
In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more
Physician recapitalization transactions are complex by nature and often present myriad issues. At Foley, in our representation of both investors in, and sellers of, physician practices, we note how often tax issues become...more
The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more
On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more
Market rumblings indicate the current economic landscape is creating challenges for startups looking to raise money. By some accounts, early-stage startups have not (yet) seen much of an impact of the tightening market,...more
On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more
The “Great Resignation” as it has been called reflects the large number of employees leaving the traditional workforce, and many of those departing employees are leaving hourly or salaried positions to start their own new...more
A company “flip” has become a ubiquitous method of accessing the U.S. markets, whether for fundraising or commercial growth. A “flip” involves formation of a corporation in the United States, typically a Delaware corporation...more
First Step- Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...more
With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more
How can legal structures help investors maximize the impact of their investments? Below, read more about key ESG concepts and best practices for stakeholders and investors to consider moving forward...more
There are many reasons a startup should begin its life as a C corporation, and yet it is not uncommon for founders to start their companies as LLCs. Founders often believe it is simpler to begin operations as an LLC and that...more
On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more
We receive many questions from founders, investors and others about qualified small business stock. And it’s no wonder, given the complexity of the concept. In this article, we provide a high-level overview of QSBS. A...more
BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...more
New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more
The Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) and the recent taxpayer victory in the U.S. Tax Court’s Lender Management, LLC decision have created important planning opportunities for both our closely held and...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more