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Prior to the One Big Beautiful Bill Act signed by President Trump on July 4, 2025 (the “OBBBA”) , Section 1202 provided that non-corporate taxpayers that acquired qualified small business stock after August 10, 1993 (“QSBS”)...more
In a recent post, available here, we discussed the basic requirements and benefits of Internal Revenue Code Section 1202, which provides for the exclusion from income of certain gains realized with respect to the sale of...more
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
Opportunity zones provide a powerful tool for taxpayers to defer recognizing their capital gains if they roll over their investment into a qualified opportunity zone fund, and offer investors the potential of avoiding...more
Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more
The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for renewable energy and other industries, as we discussed soon after the TCJA became law. ...more
A Presidential Decree by Mexico President Andrés Manuel López Obrador granting a new set of income tax incentives to capital gains and interests derived from corporate bonds (the Decree) became effective on Jan. 9, 2018. ...more
BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more
The Tax Cuts and Jobs Act signed on Dec. 22, 2017, amended the tax code to encourage economic growth and investment in designated distressed communities, called qualified opportunity zones, by providing federal income tax...more
The Treasury Department and Internal Revenue Service issued proposed regulations and other guidance on the new "opportunity zone" tax incentive on October 19, 2018. This tax incentive encourages investment in certain...more
• 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
The Tax Cuts and Jobs Act created the Opportunity Zone program, which was designed to encourage investment in economically distressed communities by allowing taxpayers to defer and potentially exclude certain portions of...more
• Holland & Knight previously published a three-part series describing the powerful new tax incentive contained in the Tax Cuts and Jobs Act for investments in low-income communities designated as "Opportunity Zones." •...more
As part of legislation enacted in early 2013 to avert the so-called “fiscal cliff,” Congress temporarily extended several beneficial tax provisions for businesses, including the research credit, the active financing exception...more