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Troutman Pepper Locke

Unlocking Tax Planning Efficiency: The New Era of Online Section 83(b) Elections

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The IRS has introduced a significant update permitting electronic filing of Form 15620 to make an election pursuant to Section 83(b) of the Internal Revenue Code. This update modernizes the compliance requirements of Section...more

Goodwin

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

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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

Patterson Belknap Webb & Tyler LLP

Section 83(b) Elections — Should You Pay Taxes Now?

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In startups and early-stage companies, founders often receive restricted equity grants as compensation for their services. With some planning, founders can potentially lower the taxes they pay on the appreciation of the...more

Wilson Sonsini Goodrich & Rosati

Understanding Section 1202: The Qualified Small Business Stock Exemption

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The “qualified small business stock” (QSBS) tax exemption under Section 1202 allows non-corporate founders and investors in certain emerging growth companies to potentially exclude up to 100 percent of the U.S. federal...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

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

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The number of taxpayers seeking the benefits of Qualified Small Business Stock (“QSBS”) has picked up steam in recent years, particularly since the Tax Cuts and Jobs Act (“TCJA”) lowered the federal corporate tax rates to...more

Rivkin Radler LLP

Sale of Mortgaged Property – Amount Realized or COD Income

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Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”? I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized....more

Bowditch & Dewey

Starting a Start-Up? Here’s One More Thing You Need to Know: The 83(b) Election

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Many people are forming start-up entities, especially in the Boston and Worcester areas, and for some, it becomes a great success story. For others, it does not. As an attorney who assists many start-ups and investors, I see...more

Freeman Law

The Tax Court in Brief - August 2021 #5

Freeman Law on

Tax Litigation: The Week of August 23 – August 27, 2021 - Tax Court Case: Estate of Charles P. Morgan, Deceased, Roxanna L. Morgan, Personal Representative and Roxanna L. Morgan v. Comm’r, T.C. Memo 2021-104 | August 23,...more

Freeman Law

The Tax Court in Brief - February 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 25 – January 29, 2021 - Costello v. Comm’r, T.C....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

Clark Hill PLC

It’s a Wonderful Life – Or is it? The Taxation of Crowdfunding

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Every holiday season, I, like many other Americans, watch Frank Capra’s classic, It’s a Wonderful Life. While the movie has a number of iconic scenes, the most heartwarming scene occurs at the end, as the citizens of Bedford...more

Jackson Walker

Life Cycle Of A Company – Choice Of Entity And Key Contents Of Organization Documents

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I. GENERAL. A. Introduction. In selecting a form of business entity for an oil patch deal in Texas the organizer or initial owners can consider the following five business entity forms: • Corporation •...more

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