News & Analysis as of

Internal Revenue Service Tax Reform Investment

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.  
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

Husch Blackwell LLP

OBBBA Extends, Modifies Opportunity Zone Program

Husch Blackwell LLP on

One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

Paul Hastings LLP

Qualified Small Business Stock Tax Benefits Expanded for Early-Stage Companies and Investors

Paul Hastings LLP on

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

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

DLA Piper

Litigation Funding Tax and Retaliatory Tax: Top Points from the Latest JCT Scores

DLA Piper on

The Joint Committee on Taxation (JCT) on June 22, 2025, released tables providing revenue estimates for provisions of the recent Senate Committee on Finance bill language (JCX-29-25) as well as those of the comparable House...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

Troutman Pepper Locke on

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

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

People like their 401(k)s

According to new research published by the Investment Company Institute (ICI), Americans like their retirement plans. ICI’s research report “American Views on Defined Contribution Plan Saving, 2024” finds that almost 75% of...more

Seward & Kissel LLP

Carried Interest in the Crosshairs…Again

Seward & Kissel LLP on

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

Ballard Spahr LLP

Your Role in Protecting Tax-Exempt Bonds During Legislative Changes

Ballard Spahr LLP on

President Trump has indicated that one of his key economic priorities is to extend the expiring provisions of the Tax Cuts and Jobs Act (TCJA). However, Congress still needs to resolve disagreements on the cost and funding of...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

McDermott Will & Schulte

Court Rules Taxpayer Can Offset Foreign Tax Credits With NIIT Liability Under Tax Treaty

McDermott Will & Schulte on

In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more

McDermott Will & Schulte

Weekly IRS Roundup April 17 – April 21, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2023 – April 21, 2023...more

Pillsbury Winthrop Shaw Pittman LLP

Senate Democrats Announce Breakthrough Bill on Energy, Climate, Tax Reform and Prescription Drug Pricing

The Inflation Reduction Act of 2022 would constitute a historic investment in the U.S. clean energy industry. If passed, the bill would be the biggest and most significant climate and energy bill ever passed by Congress....more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Cadwalader, Wickersham & Taft LLP

IRS Proposes Carried Interest Regulations

On July 31, 2020, the IRS and Treasury issued proposed regulations under section 1061 of the tax code. Section 1061 imposes a three-year holding period as a precondition to recognizing long-term capital gains on carried...more

Morgan Lewis

Opportunity Zone Fund Regulations – Long-Awaited Guidance Should Help Investors and Sponsors Get Off the Sidelines

Morgan Lewis on

The US Department of the Treasury and the Internal Revenue Service (IRS) released much-anticipated guidance on October 19 on investments in the new Opportunity Zone Funds. The release included proposed regulations...more

Mayer Brown

Tax Reform Timing - Effective Date of 2018 at the Earliest Based on History

Mayer Brown on

Rumblings in the market suggest that some tax equity investors are preparing for the possibility that the 2017 marginal corporate federal income tax rate may be much lower than the current 35 percent. Such tax equity...more

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