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Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part V – Qualified Small Business Stock Exclusion / Code Section...

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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

Paul Hastings LLP

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

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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

Offit Kurman

Equal Shares, Unequal Outcomes: Estate Planning Strategies for Parents and their Qualified Retirement Accounts

Offit Kurman on

Typically, a parent wishes to treat their children equally in their estate plan and presumes they will achieve this goal by dividing all their assets into equal shares upon their death. Accordingly, they will designate their...more

Cadwalader, Wickersham & Taft LLP

IRS Aims to End Abusive Basis-Shifting Transactions

The IRS has issued new guidance to prevent related parties from using partnerships to achieve tax benefits through basis-shifting among assets. The IRS recently released a guidance package aimed at preventing...more

Rivkin Radler LLP

Activities Contrary to Public Policy – Revoking the Tax Exempt Status of Universities

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It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Gray Reed

IRS Takes Warning Shot at Section 643(b) Trust Arrangements

Gray Reed on

For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.”  On August 9, 2023, IRS Chief...more

McDermott Will & Schulte

IRS to Update Schedule UTP to Require Additional Transparency

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On October 11, 2022, the Internal Revenue Service (IRS) announced draft changes to Schedule UTP, Uncertain Tax Position Return Statement, and Form 1120, Instructions for Schedule UTP, for the 2022 tax year (processing year...more

Rivkin Radler LLP

The Transaction That Failed – Tax Treatment of Termination Fees

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Deal Costs, Generally- Every purchase and sale of a business, whether from the perspective of the seller or the buyer, is about economics, and few items will impact the economics of the transaction more certainly or...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Make Your Year-End Charitable Gifts to Take Advantage of Expanded Tax Benefits

Because of the hardships from the COVID-19 pandemic and several weather related events, the demand on charitable organizations has increased significantly this year, increasing the need for charitable giving. Tax benefits to...more

Freeman Law

[Webinar] Legal and Tax Update - July 28th, 2:00 pm CT

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Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

McDermott Will & Schulte

Weekly IRS Roundup May 17 – May 21, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 17, 2021 – May 21, 2021... May 17, 2021: The IRS issued Revenue Ruling 2021-9, providing...more

Buckingham, Doolittle & Burroughs, LLC

SALT Cap Workaround – Ohio provides PTE investors who elect workaround with income tax benefit.

Individuals are limited to deducting $10,000 ($5,000 for married filing separate) of state and local taxes (SALT) on their Federal income tax. Generally, income earned by pass-through entities (PTE) is taxed at the investor...more

Bilzin Sumberg

What Makes a Trust a "Foreign" Trust?

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In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal...more

Bowditch & Dewey

The Tax Benefits of Giving Tuesday

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Since it began in 2012, Giving Tuesday, the Tuesday after Thanksgiving, has become more and more popular. A recent survey suggests that 62% of Americans plan to participate this year. The main purpose behind Giving Tuesday...more

McDermott Will & Schulte

Weekly IRS Roundup October 14 – October 18, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 14 – October 18, 2019. October 15, 2019: The IRS published a news release that...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

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On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Burr & Forman

Senate Finance Committee Probing Conservation Easement Abuse

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On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...more

Foster Garvey PC

Opportunity Zone Funds – Part III: Lots of Questions But Few Answers

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There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more

Holland & Knight LLP

Seven Tips for Tribal Governments to Reduce Tribal Member Taxes in 2019

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• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more

Holland & Knight LLP

Opportunity Zone Investments: What You Need to Know and Potential Scenarios - A New Opportunity for Investors to Defer Taxable...

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• The Internal Revenue Service (IRS) on Oct. 19, 2018, issued much anticipated proposed regulations (the Proposed Regulations) and other guidance on tax benefits arising from investments in "qualified opportunity zones" that...more

Akin Gump Strauss Hauer & Feld LLP

Opportunity Zones: How Communities Can Leverage This New Provision to Jumpstart Investment

• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital. • States, cities,...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VIII: Charitable and Tax-Exempt Organizations / Estate and Gift Taxes

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Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VI: Employment and Fringe Benefit Related Provisions

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BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more

Burr & Forman

South Carolina Conservation Easements for Farm and Forestry Property

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There are 12.9 million acres of commercial forestland in South Carolina. More than half of the forestland is family-owned, and 82% of private owners live on the land. The state also has about 25,000 farms, which encompass 4.9...more

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