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Significant changes in the One Big Beautiful Bill Act (“H.R. 1”) have made Section 1202 of the Internal Revenue Code an even more valuable tax break for small business owners and investors. These updates expand who can...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
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
The One Big Beautiful Bill Act (OBBBA), enacted July 4, 2025, made a number of changes to the Internal Revenue Code of 1986, as amended (the Code), including certain notable changes to the provisions of Code Section 1202 for...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 qualified small business stock (QSBS) rules can be a powerful tax planning tool, and, following the recent enactment of a signature tax law, they have become even more potent....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
President Trump signed into law the One Big Beautiful Bill Act (the “Act”) on July 4, 2025 (the “Signing Date”). Among the Act’s significant tax extensions and changes to tax law are several taxpayer-favorable revisions to...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
On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), which included revisions to Section[1] 1202 for “qualified small business stock” (QSBS) unchanged from those initially introduced in the...more
As if QSBS wasn’t good enough already, the “Big Beautiful Bill” signed into law by President Trump on July 4, 2025 enacts significant, founder-friendly changes to Section 1202 of the Internal Revenue Code, which substantially...more
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
As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...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
Many of us would like our children to inherit our home once we are gone. More than a few of us think it makes sense to give our home to our children while we are still living. That is not a good idea! Here’s why. Loss of...more
Most founders are familiar with Section 1202 of the Internal Revenue Code, which provides a tax exemption for the sale of Qualified Small Business Stock (QSBS). Less well known is Section 1202's cousin, Section 1045, which...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
UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
The 2021 Italian Budget Law aligns the tax treatment applicable to EU investment funds with the tax treatment applicable to Italian investment funds....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
Top Ten Estate Planning Recommendations before the End of 2020 - If you have not already been inundated with invitations to webinars, articles and newsletters regarding the estate planning you should consider doing before...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue...more