News & Analysis as of

Tax Planning Business Entities

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

Cadwalader, Wickersham & Taft LLP

Wyden’s Partnership Tax Bills: A Mouthful and Then Some

On June 17, 2025, Senator Ron Wyden introduced two extensive partnership tax reform bills in the Senate (collectively, the “Bills,” and available here and here).  The Bills expanded upon and incorporated many of Wyden’s 2021...more

Tarter Krinsky & Drogin LLP

New Tax Law Increases the Benefits for Qualified Small Business Stock

Benefits Offer Enhanced Tax Exclusions and Eligibility for Founders, Early Employees, and Investors- The recently enacted One Big Beautiful Bill Act makes several taxpayer-friendly revisions to the rules governing Qualified...more

Holland & Knight LLP

Conversion of Partnership and LLC Interests into Qualified Small Business Stock

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Given the recent amendments to Internal Revenue Code Section 1202,1 which increase the benefits of holding qualified small business stock (QSBS), many companies currently operating as tax partnerships may want to convert into...more

WilmerHale

Alternative Structures for Life Sciences Companies: The LLC Holding Company

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Life sciences companies (particularly early stage companies) may be attracted to an LLC holding company structure as an alternative to a typical C corporation structure to maximize both the purchase price paid by a future...more

Dickinson Wright

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

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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

Allen Barron, Inc.

Expanding Your International Business to San Diego or the United States

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Are you considering expanding your international business to San Diego or the United States? Are you planning to start a new business entity to add to the existing constellation of your companies, or are you considering a...more

Walkers

Overview of the Cayman Islands Economic Substance requirements

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Each entity incorporated, established or registered in the Cayman Islands must file an annual economic substance notification with the Tax Information Authority (the "TIA"). A "relevant entity" conducting "relevant...more

Cole Schotz

Salt Provisions In The One Big Beautiful Bill Act: A Mirage Rather Than A Panacea Of Relief For High-Income Earners

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law ushering in sweeping federal tax changes. The legislation notably expands the Qualified Business Income (QBI) deduction for professionals...more

Cozen O'Connor

Expansion of QSBS Benefits Under the One Big Beautiful Bill

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law, which had narrowly passed through the United States Congress. The OBBBA makes permanent certain tax provisions that were due to expire...more

Husch Blackwell LLP

One Big Beautiful Bill Act Expands Qualified Small Business Stock Exclusion

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On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” into law. Among notable tax legislation, the act expanded the qualified small business stock exclusion, potentially making C Corporation tax status a...more

Gould + Ratner LLP

OBBB Act Brings Significant Changes to Section 1202 QSBS Gain Exclusion

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On July 4, President Donald Trump signed the One Big Beautiful Bill Act (“OBBB”) into law. Among many changes, the OBBB included an expansion of the qualified small business stock (“QSBS”) gain exclusion under Section 1202 of...more

Wilson Sonsini Goodrich & Rosati

Understanding Section 1202: The Qualified Small Business Stock Exemption

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

Dickinson Wright

Tax Considerations in Analyzing Offers from Practice Groups

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Although in prior articles in this publication, I addressed tax issues faced by physicians and other practice groups, the purpose of this article is to guide physicians and other medical professionals as they compare the...more

Allen Barron, Inc.

Integrated Professional Services Provide Stronger Business Outcomes

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How can integrated professional services provide stronger business outcomes for your business?  Why should you consider integrated legal, tax, accounting, and business advisory services, instead of relying upon the separate...more

Cadwalader, Wickersham & Taft LLP

Taxpayers Worked Up About PTET Workarounds

The Senate’s version of the One Big Beautiful Bill Act (the “Act”) was released on June 16th, following the House’s passing of its version of the bill in late May. Among the many tax-related changes in both versions of the...more

Ward and Smith, P.A.

More Than Dirt, Seed, and Tractors: Why Today’s Farms Need Real Strategy

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But today, large-scale agricultural operations aren’t just production-focused—they’re complex businesses operating in a dynamic, heavily regulated environment. Sophisticated growers across North Carolina are managing...more

Mintz - Intellectual Property Viewpoints

Should Your Company Use an IP Holding Company? Here’s What You Need to Know

When it comes to intellectual property (IP), where your company holds its assets can be just as important as what you own. Many companies default to keeping IP within their operating entities… but is that the smartest move?...more

Hone Maxwell

Why Some International Entrepreneurs Use U.S. LLCs Without Paying U.S. Tax

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In the increasingly global world of online business, it’s not unusual for entrepreneurs, freelancers, and consultants to seek a business structure that supports international operations, offers stable banking options, and...more

Cadwalader, Wickersham & Taft LLP

Nordcurrent: Interpreting Anti-Abuse Rules

On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more

Hinckley Allen

Qualified Small Business Stock: Pre-Acquisition Planning for Tax Savings Upon Exit

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Issuing qualified small business stock (“QSBS”) is a valuable tool that can provide significant tax savings to searchers and independent sponsors alike upon the eventual sale of one or more of their portfolio companies....more

Morgan Lewis

Federal Fiscal Court Issues Two Rulings on the Requirements for a Consolidated Tax Group for Income Tax Purposes - Legal Insights...

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In two rulings, the Federal Fiscal Court (BFH) ruled in favor of the taxpayer on the requirements for a consolidated tax group for income tax purposes. Managing holding partnership as controlling company (judgment of November...more

Keating Muething & Klekamp PLL

Documentation is Key When Claiming QSBS Benefits

In recent years, the utilization of qualified small business stock (“QSBS”) under Section 1202 has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax...more

Holland & Knight LLP

Podcast - Colaborar por contrato... sí funciona

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En este episodio de "A Lo Legal En Par Minutos", el socio Edwin Cortés conversa con Sergio Alayon sobre los contratos de colaboración empresarial, una modalidad muy vigente para hacer negocios sin necesidad de constituir una...more

Walkers

The future of family offices: Evolving needs, enduring structures

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Across the globe, second and third generations are inheriting significant wealth and with it, the opportunity to professionalise how their family manages, governs and grows that wealth. Many are establishing dynamic,...more

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