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Internal Revenue Service Tax Planning Internal Revenue Code (IRC)

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Haynes Boone

IRS Reminder: Educational Assistance Programs Can Help Pay Employee’s Student Loans

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The IRS recently issued a news release with a reminder that employers may contribute up to $5,250 annually per employee toward qualified student loan repayments if provided under a Section 127 educational assistance program....more

Frost Brown Todd

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

Frost Brown Todd on

Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more

Snell & Wilmer

Electronic Filing Now Available for Section 83(b) Elections

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As explained in a prior blog, last year the IRS released Form 15620, an approved IRS form for making Section 83(b) elections under the Internal Revenue Code. Historically the IRS has required taxpayers to submit their 83(b)...more

Clark Hill PLC

EIN retention in healthcare M&A: How F-Reorganizations can preserve regulatory and tax continuity

Clark Hill PLC on

Often in healthcare transactions, retaining a federal Employer Identification Number (“EIN”) after an acquisition or restructuring is essential to the continuity of operations, regulatory compliance, and preservation of key...more

Hughes Hubbard & Reed LLP

Trump Law’s Estate Tax Exemption Is a Boon for Wealth Planning

President Donald Trump’s massive tax-and-spending package requires attention from both individuals and estate planners to advance their estate and income tax planning objectives. Originally Published by Bloomberg Law. ...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Roth Mandate Mess: AICPA Asks for Clarity on SECURE 2.0 Catch-Up Contributions

When Congress passes sweeping retirement legislation, the details often come later—and those details usually come in the form of regulatory spaghetti that plan sponsors and administrators are left to untangle. Case in point:...more

Mintz - Tax Viewpoints

New Electronic Filing Option for Section 83(b) Elections

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On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

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

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

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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

Morrison & Foerster LLP

Say Goodbye to Paper Cuts: Section 83(b) Elections May Now Be Filed Online

In late 2024, the Internal Revenue Service (IRS) introduced Form 15620 to provide a standardized mechanism for taxpayers to make elections under Section 83(b) of the Internal Revenue Code (the “Code”). More recently in 2025,...more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...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

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for the Real Estate Industry

Troutman Pepper Locke on

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...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

Goodwin

Online Filing of Section 83(b) Elections Is Here!

Goodwin on

Last year, the US Internal Revenue Service (IRS) released Form 15620 for taxpayers to make elections under section 83(b) of the Internal Revenue Code, an important part of US tax planning for founders, employees, board...more

Jones Day

The One Big Beautiful Bill Becomes Law: Key Real Estate Tax Changes

Jones Day on

Signed into law on July 4, 2025, the One Big Beautiful Bill Act (the "Act") permanently extends and modifies several cornerstone provisions of the Tax Cuts and Jobs Act of 2017, restores key business incentives, and makes...more

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for Investment Funds and Sponsors

Troutman Pepper Locke on

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more

Rivkin Radler LLP

Closely Held Businesses and Their Owners Ask: What’s Big and Beautiful in the Recent Tax Law?

Rivkin Radler LLP on

The “One Big Beautiful Bill Act” (the “Act”) was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were...more

Ballard Spahr LLP

President Trump’s Budget Extends His 2017 Individual Tax Provisions

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President Trump signed into law what is commonly referred to as the One Big Beautiful Bill Act (OBBBA), extending provisions from the Tax Cuts and Jobs Act of 2017 otherwise set to expire at the end of this year. The new...more

Frost Brown Todd

One Big Beautiful Bill Act Enacts a Permanent Increase in the Estate and Gift Tax Lifetime Exclusion Amount for 2025 and Later...

Frost Brown Todd on

On July 3, 2025, and by a vote of 218 to 214, the U.S. House of Representative passed the Senate’s amended version of H.R. 1 (also known as the “One Big Beautiful Bill Act” or OBBBA 2025), which is the tax-and-budget...more

Baker Botts L.L.P.

The "One Big Beautiful Bill Act" Substantially Alters Clean Energy Tax Landscape

Baker Botts L.L.P. on

On July 4, 2025, the legislation commonly known as the "One Big Beautiful Bill Act" (the “BBBA”) was enacted. The BBBA makes significant changes to the tax credits available under the Inflation Reduction Act of 2022 (the...more

Holland & Knight LLP

AbbVie's Tax Triumph: Breaking Free from Capital Loss Limitations

Holland & Knight LLP on

In a significant win for taxpayers, the U.S. Tax Court recently ruled in AbbVie Inc. v. Commissioner, Docket No. 2597-23, that a $1.6 billion "Break Fee" paid by AbbVie qualifies as an ordinary and necessary business expense...more

Cadwalader, Wickersham & Taft LLP

Congress Targets Partnership Disguised Sales and Services

Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more

Holland & Knight LLP

IRS Issues Updates for Energy Community Bonus Tax Credit

Holland & Knight LLP on

The IRS released additional guidance on June 23, 2025, in the form of Notice 2025-31 (Notice) regarding the energy community bonus credit under Sections 45, 48, 45Y and 48E of the Internal Revenue Code. The Notice follows...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

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