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Mayer Brown

Tax Law Highlights - Impact of the Tax Reform on Administrative and Judicial Litigation: Jurisdiction and Related Issues

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ADMINISTRATIVE LITIGATION - Introduction: Tax Reform and the Possible Increase in Litigation; Operation of IBS tax inspection...more

Cadwalader, Wickersham & Taft LLP

Wyden’s Partnership Tax Bills: A Mouthful and Then Some

On June 17, 2025, Senator Ron Wyden introduced two extensive partnership tax reform bills in the Senate (collectively, the “Bills,” and available here and here).  The Bills expanded upon and incorporated many of Wyden’s 2021...more

McDermott Will & Schulte

Carried interest in the UK: The new average holding period (AHP) condition for credit funds

The UK tax regime for carried interest is being substantially revised from April 2026. This Alert focuses on one particular aspect: the changes to how credit funds should calculate the average holding period (AHP) of their...more

Frost Brown Todd

Section 1202 and QSBS: A Survey of States That Don’t Conform to the Federal Treatment

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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

K&L Gates LLP

Europe: Fundamental Reform of UK Taxation of Carried Interest

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From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was...more

Jackson Walker

One Big Beautiful Bill Act Increases Deduction for State and Local Tax but Fails to Address Nexus Concerns

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In welcome news for individual taxpayers, the One Big Beautiful Bill Act temporarily increases the “SALT cap” – the limit on the amount of the income tax deduction for state and local income, sales, and property taxes – from...more

Proskauer Rose LLP

UK Tax Round Up - July 2025

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Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more

Brownstein Hyatt Farber Schreck

Taxation & Representation, July 2025 #3

Speaker Johnson Kicks Off Discussions for Reconciliation 2.0: House Republicans are laying the groundwork for a second reconciliation bill this fall that aims in part to revive key provisions excluded from the One, Big,...more

Hone Maxwell

Understanding the One Big Beautiful Bill Act: GILTI Becomes Net CFC Tested Income (NCTI)

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Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more

Fox Rothschild LLP

IRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces Retirement

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The Internal Revenue Service continues to experience significant leadership transition during a period of ongoing internal upheaval and uncertainty. The latest developments are the appointment of Kenneth Kies as the new...more

Hogan Lovells

UK carried interest regime: draft legislation confirms scope and conditions

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On 21 July 2025, the UK Government published draft legislation for the new UK carried interest regime, which is expected to come into effect from 6 April 2026. As previously announced, the draft legislation provides for...more

Ropes & Gray LLP

French Tax Administration Issues Draft Comments on Management Package Tax Reform

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On July 23, 2025, the French Tax Administration released its initial draft guidance in the BOFiP (Bulletin Officiel des Finances Publiques) (the “Tax Comments”) on the new tax regime for Management Packages introduced by the...more

Holland & Knight LLP

Florida HB 7031 Becomes Effective Oct. 1, 2025

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In a major win for Florida's commercial real estate market, Gov. Ron DeSantis signed Florida House Bill (HB) 7031, eliminating both the State Business Rent Tax and County Surtax on commercial leases effective Oct. 1, 2025....more

Foley Hoag LLP

Tax Benefits of QSBS Expanded under the “One Big Beautiful Bill Act”

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Key Takeaways: - On July 4, 2025, “The One Big Beautiful Bill Act” (the “Act”) was signed into law, introducing significant expansions of the tax benefits of “qualified small business stock” (“QSBS”) issued on or after July...more

Royer Cooper Cohen Braunfeld LLC

One Big Beautiful Bill Expands Key Tax Incentives Including Section 1202 Qualified Small Business Stock and Qualified Opportunity...

The reconciliation bill, known as the “One Big Beautiful Bill” (the “BBB”), was recently signed into law on July 4th. The BBB, among many other things, made significant changes in tax law, building on the foundations created...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, July 2025 #2

Passthrough Deduction Eyed for Bigger Boost in Future Bill: House Republicans are weighing the possibility of a second major tax package following the recent enactment of their One, Big, Beautiful Bill Act (OBBBA, Public Law...more

Cadwalader, Wickersham & Taft LLP

House Ways and Means to Crypto’s Rescue on Taxes?

On July 16, 2025, the House Ways and Means Committee held a hearing on crypto taxation. Congress and the Administration did not address tax issues in the most recent Digital Asset legislation, as previously discussed here. ...more

Blank Rome LLP

One Big Beautiful Bill Act: Key Business, International, and Employment Tax Provisions

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The federal government enacted the One Big Beautiful Bill Act (the “Act”) on July 4, 2025. The Act extends and makes permanent certain tax provisions introduced in the Tax Cuts and Jobs Act (the “TCJA”) that were scheduled to...more

Proskauer - Tax Talks

President Trump Signs One Big Beautiful Bill Act into Law

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. The Act is similar to the Senate Finance Committee’s draft legislative text (the “SFC Bill”) (released on June 16, 2025), with...more

BCLP

Qualified Small Business Stock Benefits Expanded Under the One Big Beautiful Bill Act

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. Among the many changes, the Act expands the favorable tax treatment for Qualified Small Business Stock (“QSBS”) under Section 1202...more

Clark Hill PLC

Crypto taxes take center stage

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On July 16, the House Ways and Means Oversight Subcommittee held a hearing titled Making America the Crypto Capital of the World: Ensuring Digital Asset Policy Built for the 21st Century. The hearing confronted the widening...more

Cozen O'Connor

Tax Provisions Under One Big Beautiful Bill Affecting Real Estate Investment

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The enacted One Big Beautiful Bill (H.R.1, O3B) amends current tax law provisions and adds other provisions that affect real estate investments. This alert is intended to provide a summary of tax items under O3B of interest...more

Fox Rothschild LLP

IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful

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A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with a 2022 Treasury...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

Brownstein Hyatt Farber Schreck

Taxation & Representation, July 2025

Trump Signs OBBBA Into Law: On July 4, 2025, President Trump signed H.R. 1, the One, Big, Beautiful Bill Act (OBBBA), into law, codified as Public Law 119-21. The tax title of the legislation makes several provisions from the...more

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