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Stock qualifying under Section 1202 of the Internal Revenue Code of 1986, as amended (the “Code”), as Qualified Small Business Stock (“QSBS”) allows eligible non-corporate taxpayers to potentially exclude a portion or all of...more
The Section 1202 exclusion is one of the most valuable tax planning tools available to U.S. business owners and investors. It allows a non-corporate taxpayer (e.g., an individual or trust) to eliminate federal capital gains...more
After months of intense negotiations, on July 4, 2025, the One Big Beautiful Bill (OBBB) was signed into law making various changes to the tax code that impacts estate, gift and income tax planning. Increased Estate, Gift...more
The long-anticipated “sunset” of the Tax Cuts and Jobs Act of 2017 (TCJA) was slated for the end of 2025. Upon this “sunset,” the federal estate and gift tax exemptions—which reached $13.99 million per individual in...more
Qualified Small Business Stock (QSBS) offers business owners significant federal tax benefits of exclusion of up to $10 million or ten times the stock’s basis in capital gains, whichever is greater. The stock must be held for...more
This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more
The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more
The IRS has issued Revenue Procedure 2022-38, which sets forth inflation-adjusted items for various provisions of the Internal Revenue Code which will be applicable in 2023. Here are some of the highlights...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more
It is said that two things are certain in life: death and taxes. True, but incomplete. What is missing from this short list is a third inevitable occurrence – tax law changes. We now have a new and pressing series of proposed...more
Significant tax reform could be imminent, depending on whether Biden or Trump wins next month’s election and which party controls Congress. Joe Biden’s tax plan proposes changes that would drastically impact wealth transfer...more
As part of his campaign platform, Democratic Presidential nominee Joe Biden has released a tax plan that would significantly increase taxes on high net worth individuals. Although a campaign platform is only a “rough draft”...more
2019 Key Pennsylvania Figures - Pennsylvania Inheritance Tax Rates: Transfers between spouses - 0% (jointly held property between spouses is not subject to tax). Transfers from child 21 or under to parent - 0%. ...more
It has been a busy week in Washington, D.C., as Congress works its way through tax reform. The House Ways and Means Committee completed its "markup" of the House bill this week, paving the way for a floor vote on the measure...more
The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more