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Tax Liability Tax Planning

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

Baker Donelson

IRS Streamlines 83(b) Election Process with New Online Filing Option

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The Internal Revenue Service (IRS) continued recent improvements to the process for making elections under Section 83(b) of the Internal Revenue Code of 1986 (the Code). Until last year, an 83(b) election was made in a...more

Lasher Holzapfel Sperry & Ebberson PLLC

Family Investment Vehicles in Limbo: Awaiting Department of Revenue Guidance

The legal landscape for family investment vehicles in Washington shifted dramatically after the Antio LLC v. Department of Revenue decision of the Washington Supreme Court. In Antio the taxpayers were a group of investment...more

Allen Barron, Inc.

IRS and State Tax Complications of Offshore Investments

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What do you need to know about the IRS and state tax complications of offshore investments? It is common to have international investments in your portfolio, not to mention business interests. How do you navigate the...more

Roetzel & Andress

Social Security Still Taxed Under One Big Beautiful Bill Act

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As many people may remember one of Donald Trump’s campaign promises during the 2024 election was that he would eliminate taxes on social security. That did not happen. Instead, the recently enacted One Big Beautiful Bill Act...more

Frost Brown Todd

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

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Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more

Jackson Walker

Income Tax Changes Warrant Consideration When Awarding Equity Incentives

Jackson Walker on

Tax law is an interrelated web of complex rules, and changes in one rule can impact compensation strategies for management and executives even if the change is to individual income tax calculation rules. Executives should...more

ASKramer Law

Tax-Loss Harvesting Part III: Investment Strategies

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Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment  returns, while offsetting...more

Butler Snow LLP

The One Big Beautiful Bill Act and Its Potential Business Impact

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “OBBB”) into law. While technically a budget reconciliation law, the OBBB is a significant piece of legislation that prioritizes this...more

Dickinson Wright

Tax Planning Misstep? Ontario Court of Appeal Says No to Rectification

Dickinson Wright on

A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more

Haynes Boone

Federal Estate, Gift and GST Tax Highlights from the One Big Beautiful Bill Act

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The recently enacted One Big Beautiful Bill Act (OBBBA) brings sweeping and permanent changes to the federal estate, gift and generation-skipping transfer (GST) tax landscape. Most notably, it significantly increases the...more

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

Hone Maxwell on

Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Kilpatrick

5 Key Takeaways: Business and Nonbusiness Income

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Kilpatrick’s Jordan Goodman recently co-presented the session “Income Subject to Allocation” at the Institute for Professionals in Taxation’s “2025 State Income Tax School” in Atlanta. Jordan addressed the distinction between...more

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

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At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more

DLA Piper

What the One Big Beautiful Bill Act’s Tax Provisions Mean for Businesses Operating in Puerto Rico

DLA Piper on

President Donald Trump recently signed into law the bill commonly known as the One Big Beautiful Bill Act (OBBBA). On July 4, 2025, the OBBBA made permanent many of the provisions of the Tax Cuts and Jobs Act of 2017 (TCJA)...more

Mintz - Employment Viewpoints

409A Risks with Relocation Reimbursements

As employers increasingly focus on in-person office mandates, reimbursements for relocation expenses have once again become a key component of attracting top talent. If not carefully structured, however, such expense...more

Morgan Lewis

No Gift Tax on Increases in the Value of Shares in the Case of Shareholder-Allocated Contributions

Morgan Lewis on

In a proceeding for suspension of enforcement, the Federal Fiscal Court (BFH) has concluded that also disproportionate contributions into the capital reserve do not constitute a gift tax-relevant increase in the value of...more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

ASKramer Law

Tax-Loss Harvesting Part I: Overview

ASKramer Law on

What is tax-loss harvesting? “Tax-loss harvesting,” in its simplest form, is the sale of a capital asset at a loss to “mop up” tax that would otherwise be due on capital gain from the sale of another capital asset. Capital...more

Mintz - Employment Viewpoints

Navigating Massachusetts Taxes after Relocation: Key Takeaways from Welch v. Commissioner of Revenue

Many Massachusetts residents have recently considered taking, or have undertaken, steps to relocate from Massachusetts to jurisdictions with lower or no state income taxes, especially in light of the recently enacted 2023...more

Holland & Knight LLP

Washington State Budget Triggers Higher Business, Capital Gains and Estate Taxes in 2025

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Thanks to three primary revenue bills that were signed into law earlier this year, taxes are going up in the state of Washington, in particular for large service businesses, estates and individuals earning capital gains. ...more

Stinson LLP

Missouri Eliminates Capital Gains Tax

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On July 10, 2025, Missouri Gov. Mike Kehoe signed House Bill 594, which will exclude both short- and long-term capital gains from Missouri individual income tax and, in certain circumstances, corporate income tax....more

Bilzin Sumberg

Key International Tax Changes From the One Big Beautiful Bill Act

Bilzin Sumberg on

On July 4th, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”). This alert expands upon our Firm’s prior alert and is intended to summarize the main tax law changes that may impact: (i) U.S....more

BakerHostetler

[Podcast] An Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

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The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more

Shumaker, Loop & Kendrick, LLP

The Estate Planner, July/August 2025

Handle an inherited IRA with care - An inherited IRA can be a welcome financial windfall. But the rules governing required minimum distributions (RMDs) from these tax-deferred accounts are complex. IRA recipients should...more

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