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Internal Revenue Service Venture Capital

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.  
Ballard Spahr LLP

Initial Insights Into the One Big Beautiful Bill: Key Provisions for Private Equity Funds and Fund Sponsors

Ballard Spahr LLP on

Recently, President Donald Trump signed the bill known as the One Big Beautiful Bill Act (OBBBA) into law. OBBBA permanently extends many provisions of the Internal Revenue Code (Code) introduced by the Tax Cuts and Jobs Act...more

Hanson Bridgett

United States Tax Planning for Foreign Founders Moving to the US: Planning for Qualified Small Business Stock Benefits

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Many non-US startup founders initially incorporate in their home country and then decide to reincorporate or create a subsidiary in the US. There are many advantages for foreign founders to move operations to the US,...more

DarrowEverett LLP

Unlocking Tax-Free Gains: The Power of QSBS in Mergers & Acquisitions

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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

Farrell Fritz, P.C.

Qualified Small Business Stock – Overview and Useful Strategies

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Founders, entrepreneurs, venture capitalists and other investors (all of which are collectively referred to herein as “investors”) should be familiar with Internal Revenue Code Section 1202, a valuable provision that...more

DLA Piper

2025 Carried Interest Tax Reform and Impact on Sponsors and Investors

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On February 6, 2025, President Donald Trump met with Republican lawmakers to discuss budget priorities, proposing to end carried interest. On the same day, Democrats introduced bills in both the House and the Senate that...more

Wilson Sonsini Goodrich & Rosati

Eligibility of Life Sciences Companies for Qualified Small Business Stock

The “qualified small business stock” (QSBS) tax exemption under Section 1202 of the Internal Revenue Code allows non-corporate founders and investors in certain emerging growth companies organized as corporations to...more

Orrick, Herrington & Sutcliffe LLP

What's the Best Transaction Structure for My Sale?

Sit down with Eric Wall and Mark Seneca for insights on: Tax advantages and disadvantages for stock vs. asset sales The most common deal structure for VC-backed company sales and why Structuring a “tax-free” transaction...more

Pillsbury Winthrop Shaw Pittman LLP

Developments in Association Law 2022 – 2024

The following is a review of notable cases and regulatory developments for nonprofit organizations at the federal and state levels during the last two years....more

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

DLA Piper on

The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Mintz - Venture Capital & Emerging Companies...

Section 409A Valuations: Mastering the Art and Science in a Volatile Venture Market

Within the unpredictable landscape of start-ups and private companies, market volatility can significantly alter a company’s financial trajectory. An integral part of navigating this volatility is understanding the role and...more

Alston & Bird

How Is Congress Trying to Regulate Private Equity in Health Care?

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Our Health Care Group investigates congressional efforts to require new transparency disclosures to the IRS from private equity firms invested in health care....more

Perkins Coie

Washington Court of Appeals Limits B&O Tax Deduction for Investment Income

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The Washington Court of Appeals has held that investment funds are subject to Washington state business and occupation (B&O) tax on their investment income. Although Washington law allows taxpayers to deduct “amounts derived...more

Morrison & Foerster LLP

What Is an 83(b) Election, and Do I Need to File One?

If you’re reading this, chances are this is not the first time you’ve heard of the 83(b) election (and if it is, then definitely keep reading). The “83” in “83(b) election” refers to Section 83 of the Internal Revenue Code,...more

Foster Garvey PC

Sports & Entertainment Spotlight - April 2021 #3

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“Happy” Tax Day to those of you here in the United States celebrating/commiserating (noting of course that certain taxpayers have until May 17 to file their returns this year). Like taxes, this installment of the Spotlight...more

Bass, Berry & Sims PLC

Key Considerations for Emerging Companies: Formation and Structure

Monetizing a business concept presents numerous considerations for ambitious entrepreneurs, but with careful forethought, founders can spend more time growing their business and less time worrying whether they made an...more

Foley & Lardner LLP

Telehealth Companies Should Read This New IRS Tax Ruling

Foley & Lardner LLP on

On December 4, 2020, the IRS released a new private ruling (PLR 202049002), holding that a physician-owned medical services professional corporation (PC) could be included in a consolidated tax return filing along with the...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

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U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

Fenwick & West LLP

Fenwick’s Top 10: Our Most Popular Articles of 2019

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In 2019, we published analysis to help tech and life sciences companies navigate U.S. tax law changes, an evolving IP landscape and new privacy regulations such as the California Consumer Privacy Act. We also tracked venture...more

Proskauer - Tax Talks

Proposed Regulations on Built-in Gains and Losses under Section 382(h)

Proskauer - Tax Talks on

On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under...more

A&O Shearman

Proposed Section 382 Regulations Would Eliminate Section 338 Approach of Notice 2003-65

A&O Shearman on

On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously...more

Wilson Sonsini Goodrich & Rosati

IRS Proposes Regulations That Would Limit Utilization of NOLs After Acquisitions and Other Ownership Changes

On September 9, 2019, the U.S. Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (the Proposed Regulations) that, if finalized, would significantly change the way corporations...more

Jones Day

Favorable Net Operating Loss Utilization Rules Could be Eliminated

Jones Day on

Proposed regulations, if adopted, would impose substantial restrictions in many cases on a corporation's use of existing net operating losses and similar tax attributes after a substantial change in ownership. On September...more

Bracewell LLP

Bracewell Tax Report - January 2019

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Miles & Stockbridge P.C.

Opportunity Funds: Incentive For Investment in Underrepresented Founders

With the recent passage of the Opportunity Zone Legislation and the subsequent proposed regulations that were released on October 19, 2018, private investors have, justifiably, been eager to understand and establish the...more

Cooley LLP

Blog: Changes to Handling of Underpayment of Taxes by VC Funds, and to the Concept of the “Tax Matters Partner”

Cooley LLP on

Certain important changes took effect on January 1, 2018 regarding underpayment of taxes by partnerships as well as the handling of tax inquiries including audits. The biggest change is that the IRS can now come to collect...more

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