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On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (the “OBBB”), which makes a number of highly beneficial changes to the tax treatment of Qualified Small Business Stock (“QSBS”) acquired by...more
On July 4, President Donald Trump signed a budget reconciliation bill entitled the “One Big, Beautiful Bill Act” (the Act). The Act extends the tax cuts that were enacted as part of the Tax Cuts and Jobs Act of 2017, adds a...more
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
One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more
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
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
On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the OBBBA) into law, enacting extensions of the Tax Cuts and Jobs Act of 2017, as well as a broad set of tax reforms. ...more
The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, establishes new phased-in benefits for Qualified Small Business Stock (QSBS) held for at least three years. ...more
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
As part of the newly enacted One Big Beautiful Bill Act (the OBBBA),[1] Congress adopted the first substantive amendments to Section 1202[2]–which prescribes the qualified small business stock (QSBS) rules–in over a decade...more
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
On June 16, 2025, the Senate Finance Committee released its draft legislative text (the Senate Proposal) following the prior passage of the One Big Beautiful Bill Act by the House of Representatives (the House Bill). ...more
As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more
Dans une décision du 12 mars 2025, le Conseil d'Etat confirme que si l'inscription initiale de titres en titres de participation constitue une erreur délibérée, la société ne peut bénéficier des effets d'une rectification de...more
The focus of this article illustrates why private placement life insurance (“PPLI”) is the best asset to utilize in the “Buy, Borrow and Die” strategy for high net worth investors including billionaires. After this article,...more
Internal Revenue Code (IRC) Section 1202 offers a significant tax incentive for investors in qualified small business stock (QSBS). This provision allows eligible shareholders to exclude up to 100% of capital gains realized...more
The Israel Tax Authority (ITA) recently published updated guidelines, regarding tax aspects applying to investments in companies through SAFEs. Such guidelines were published following the previous guidelines published by the...more
On February 6, 2025, Democratic Senators and Representatives proposed the Carried Interest Fairness Act, which would treat carried interest as ordinary income. Additionally, on the same day President Trump met with...more
Dans une décision mentionnée aux tables du Recueil Lebon, le Conseil d'Etat affirme la légalité de la doctrine administrative du 3 avril 2024, selon laquelle doivent être prises en compte, pour le calcul de la plus-value...more
Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...more
Income from all sources is considered when calculating a monthly child support amount under the Pennsylvania Support Guidelines. Some child support cases are complex because a party has different sources of income beyond W-2...more
On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more
Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more
As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more