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DLA Piper

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

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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

Morgan Lewis

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

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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

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part V – Qualified Small Business Stock Exclusion / Code Section...

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In this fifth installment of my multi-part series on the One Big Beautiful Bill Act, Steve Nofziger and I discuss a provision of the Act that impacts certain business owners who are contemplating a sale of their shares, Code...more

Paul Hastings LLP

REIT All About It: One Big Beautiful Bill — Tax Updates for REITs

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On July 4, 2025, President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law, following the approval of Congress. OBBBA contains the following compelling updates from a real estate investment trust (REIT)...more

Foster Swift Collins & Smith

Comparative Summary of Equity Incentive Plans for Private Companies

Equity incentive plans are a powerful tool for encouraging and rewarding a company’s employees and leadership, who may include prospective investors, through different kinds of equity interests and structures. Different...more

Maynard Nexsen

Taking the Pulse, A Health Care and Life Sciences Video Podcast | Episode 242: Business Planning in Healthcare & Life Sciences...

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This week, Lynnsey and Lauren are joined by Maynard Nexsen attorney Jennifer McEwen, who helps clients with business planning, estate and trust planning, and tax planning. Jennifer shares essential business strategies for...more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Employee Stock Ownership Plans (ESOPs) Explained

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Thinking about succession planning, employee engagement, or selling your business? On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt is joined by Nona Massengill, a partner focusing on Executive...more

Walkers

Channel Islands a strategic hub for employee share incentive plans

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In today’s competitive business environment, share incentive plans continue to be a popular tool for aligning employee interests with those of management and shareholders. Guernsey and Jersey, as leading offshore financial...more

Foley & Lardner LLP

One Big Beautiful Bill Updates to Qualified Small Business Stock Rules under Section 1202

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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

Wilson Sonsini Goodrich & Rosati

The One Big Beautiful Bill: Tax Provisions in Final Legislation Impacting Domestic and Multinational Businesses

On July 4, 2025, President Trump signed H.R. 1, commonly known as the “One Big Beautiful Bill Act” (OBBB), into law. OBBB was initially approved by the House of Representatives on May 22, 2025 (the House Bill), followed by...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

DarrowEverett LLP

Keeping It in the Family (Trust): Additional Considerations for Contributing S Corp Shares

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A large part of business sucession planning is structuring the transfer of business ownership. While outright transfers can be less complex, transferring ownership in trust can provide practical benefits that are worth...more

Pillsbury - Propel

Founder Secondary Sales: A Primer

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Increasingly, founders desire liquidity with respect to a portion of their equity stake before the company goes public or completes a complete exit event (like an M&A sale). Liquidity is desired for many reasons, including...more

Vinson & Elkins LLP

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

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On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more

DarrowEverett LLP

Business Succession Planning: Pros and Cons of Passing S Corp Shares in Trust

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Business succession planning and estate planning are often linked together, particularly in the case of closely held family businesses. In the case of a shareholder who wishes to pass along their shares of an S corporation as...more

Paul Hastings LLP

Biotech Spin-Off Transactions

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As we previously discussed (here and here), the biotech mergers and acquisitions market currently faces significant headwinds. These challenges include frozen capital markets, regulatory uncertainty at the Food and Drug...more

Walkers

Thinking ahead: Key considerations for winding up Guernsey investment funds

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The process of winding up a Guernsey fund involves several important considerations that boards, fund managers, investment advisers and administrators must navigate carefully. This article explores six aspects which we...more

Wilson Sonsini Goodrich & Rosati

Key UK Tax Implications of the Delaware Flip

U.S. venture capitalists investing at the early stages (Seed and Series A) in a UK (or other non-U.S.) company often require that the company “flips” its corporate structure and establishes a U.S. (most commonly Delaware)...more

Rivkin Radler LLP

Terminating a Trust? Don’t Forget to Consider This Tax Issue

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Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more

McDermott Will & Schulte

Economic Ownership of Shares Transferred as Collateral

Dividends from shares are taxable for shareholders, even if the dividends do not remain with them economically. This (not entirely new) finding can be gleaned from a recent Federal Fiscal Court (BFH) ruling in which the...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

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

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Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Walkers

Intergenerational wealth transfer planning part 1: By failing to prepare you are preparing to fail

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As widely reported, the coming years will likely see a significant transfer of assets and wealth across generations. Each family's circumstances will ultimately determine the nature and extent of these transfers, and any...more

Warner Norcross + Judd

Hot Topics for Private Clients and Family Offices from the 2025 Heckerling Institute on Estate Planning – Part Two

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In our previous blog post on the 2025 Heckerling Institute on Estate Planning, we highlighted the concept of purpose trusts, a conference topic involving unique planning and charitable opportunities. In this second post of...more

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