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On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (the “OBBB”), which makes a number of highly beneficial changes to the tax treatment of Qualified Small Business Stock (“QSBS”) acquired by...more
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
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 recently signed One Big Beautiful Bill Act (OBBBA) implements significant changes under Section 1202 of the Internal Revenue Code of 1986 (Code), applicable to qualified small business stock (QSBS) issued on or after July...more
The One Big Beautiful Bill Act, signed into law on July 4, 2025, by President Donald Trump, delivers sweeping changes to the U.S. tax code, with major implications for businesses — particularly regarding solar and wind tax...more
In a move to bolster investment in small business, the “One Big Beautiful Bill Act” (“OBBBA”), signed into law on July 4, 2025 (the “Applicable Date”), introduced significant changes to the Qualified Small Business Stock...more
On July 4, 2025, President Trump signed H.R. 1—referred to as the “One Big Beautiful Bill Act” (OBBBA)—which permanently renewed and modified the federal Opportunity Zone tax incentive program that was set to expire at the...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
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
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
Practitioners, operators and investors in the commercial real estate space are well familiar with Opportunity Zones and how they can be utilized for preferential tax treatment on investments. First created under the 2017 Tax...more
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
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
When it comes to the taxation of stock options, the Internal Revenue Code (Code) does not define capital assets. Rather, it identifies those assets that are not capital assets. ...more
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
The United States is no stranger to capital from foreign investors. Perhaps in South Florida especially, this is no more evident than in the real estate market, particularly when it comes to investors from Latin America. Over...more
An art collector looking to sell or exchange one or more works from his or her collection may be able to defer recognition of the capital gains on the transaction thanks to a recent change in the tax laws....more
As an update to our Legal Insight of December 2015 'New Tax Incentives for Early Stage Investment', on 16 March 2016 the Turnbull Government introduced legislation providing significant tax incentives to promote local and...more