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Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...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 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 Tax Cuts and Jobs Act (“TCJA”), which was signed into law on December 22, 2017, made some of the most significant changes to the tax law since the Tax Reform Act of 1986. Absent further legislation, many of the provisions...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA), the most significant US tax overhaul since the 2017 Tax Cuts and Jobs Act (TCJA). The OBBBA includes critical changes impacting family offices,...more
On July 4, 2025, President Trump signed into law the “One Big Beautiful Bill Act” (the “2025 Act”). The Act makes permanent some provisions originally enacted in 2017 as part of the Tax Cuts and Jobs Act (the “2017 Act”),...more
In this second installment of our multi-part series on the One Big Beautiful Bill Act (the “Act”), my colleague David Knutson and I discuss the changes made by the Act to the federal estate and gift tax regime....more
As you may be aware, on July 4, 2025, a landmark piece of tax legislation – commonly referred to as “One Big Beautiful Bill Act” – was signed into law, ushering in some of the most significant changes to the tax code in...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
A lesser-known financial upside of Continuing Care Retirement Community (CCRCs) is the potential tax deductibility of a portion of the entrance fee and monthly fees....more
In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more
Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more
La Loi de finances pour 2025 (LF 2025) a été publiée au Journal Officiel le 15 février 2025. Le présent bulletin décrit brièvement une sélection de mesures fiscales qu’elle contient....more
On 12/19/24, anticipating the 2025 filing season, the IRS published Tax Preparation 2025 Useful Pointers in IR-2024-311: Prepare to file in 2025: Get Ready for tax season with key updates, essential tips. As the 2025 filing...more
The federal estate and gift tax exemption changes from year to year. The current combined federal estate and gift tax exemption amount of $13.99 million per person ($27.98 million per married couple) is scheduled to “sunset”...more
Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more
On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more
Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and episode 107 is the first in a series of technical episodes describing the basic principles of the tax on unrelated business income generated...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 25, 2024 – December 13, 2024....more
Clients are often interested in gifting to their loved ones not only to benefit the recipient of the gift, but also to reduce the donor’s taxable estate for estate tax purposes. Every taxpayer can give a certain amount each...more
The IRS recently issued the 2025 annual adjustments for numerous tax provisions, including changes to tax brackets and standard deductions. Popular adjustments include: - Estates of decedents who die during 2025 will have...more
Estate planning is a lot like putting together a puzzle. The client provides you with their box lid showing what they want the ultimate result of their plan to look like. Then, estate planners are tasked to identify and...more
The federal estate and gift tax exemption is the highest it has ever been. Under current law, you may transfer almost $14 million to anyone you wish without having to pay a dime of federal gift or estate tax. Absent any...more