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Taxation Capital Gains Tax

Latham & Watkins LLP

French Tax Authorities’ Guidelines Clarify the New Legal Framework Applicable to Management Package Instruments

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The regime sets new rules regarding the taxation of gains realized on the sale of securities held by employees or executives in the frame of management packages....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

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

Morrison & Foerster LLP

Say Goodbye to Paper Cuts: Section 83(b) Elections May Now Be Filed Online

In late 2024, the Internal Revenue Service (IRS) introduced Form 15620 to provide a standardized mechanism for taxpayers to make elections under Section 83(b) of the Internal Revenue Code (the “Code”). More recently in 2025,...more

Barnea Jaffa Lande & Co.

Sibling Share Transfers Tax-Exempt—even via Parents

A recent district court ruling broadened the interpretation of the statutory provisions governing exemptions from land appreciation tax and ruled that transfers of shares of a real estate association as a gift between...more

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for Private Equity Funds and Their Portfolio Companies

Troutman Pepper Locke on

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

Proskauer Rose LLP

UK Tax Round Up - June 2025

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Welcome to the June edition of our UK Tax Round Up, which discusses HMRC’s response to its consultation on the new UK carried interest regime to be introduced next year and interesting cases on the main purpose test in the...more

Freeman Law

2025 Texas Legislative Update | Proposed Constitutional Amendments Relating to State Taxes

Freeman Law on

The 89th regular session of the Texas Legislature has voted to put some proposed constitutional amendments relating to state taxation on the ballot for the election on November 5, 2025. Let’s take a look....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

Warner Norcross + Judd

Diversification and Tax Savings with a 1031 UPREIT

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A 1031 UPREIT (Umbrella Partnership Real Estate Investment Trust) transaction allows real estate investors to exchange property on a tax-deferred basis under IRS Section 1031 while gaining diversification and liquidity by...more

Fox Rothschild LLP

Washington State to Raise Capital Gains, Estate Tax Rates

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By June 7, 2025, Gov. Bob Ferguson is expected to sign legislation into law that would increase funding for Washington State's Education Legacy Trust Account (ELTA) by raising the capital gains and estate tax rates. ...more

McDermott Will & Schulte

Taxation of the Purchase and Sale of NFTs

Given a lack of guidance on the tax treatment of non-fungible tokens (NFTs), taxpayers can be forgiven for experiencing a certain level of uncertainty with respect to how the Internal Revenue Service (IRS) will apply its tax...more

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