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Taxation Internal Revenue Code (IRC)

Eversheds Sutherland (US) LLP

Entering the Digital (Asset) Age: White House Report Recommends Changes to the Taxation of Digital Assets

The President’s Working Group on Digital Asset Markets recently issued a detailed report, titled “Strengthening American Leadership in Digital Financial Technology,” recommending regulatory and legislative proposals to...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

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

Clark Hill PLC

EIN retention in healthcare M&A: How F-Reorganizations can preserve regulatory and tax continuity

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Often in healthcare transactions, retaining a federal Employer Identification Number (“EIN”) after an acquisition or restructuring is essential to the continuity of operations, regulatory compliance, and preservation of key...more

Proskauer - Tax Talks

Eighth Circuit Affirms Mayo Clinic’s “Educational Organization” Status and UBTI Refund

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On July 25, 2025, the U.S. Court of Appeals for the Eighth Circuit affirmed the District Court decision holding that the Mayo Clinic is entitled to an $11.5 million refund of certain unrelated business income taxes imposed on...more

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

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Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Littler

Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

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In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Holland & Knight LLP

Conversion of Partnership and LLC Interests into Qualified Small Business Stock

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Given the recent amendments to Internal Revenue Code Section 1202,1 which increase the benefits of holding qualified small business stock (QSBS), many companies currently operating as tax partnerships may want to convert into...more

Mintz - Tax Viewpoints

New Electronic Filing Option for Section 83(b) Elections

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On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more

DarrowEverett LLP

The Earnout Equation: Tax Tips for Both Buyers and Sellers

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Earnouts are a form of contingent consideration that the buyer of a business pays to the seller in the period following the acquisition, based on the business achieving various financial metrics related to its performance...more

Mayer Brown

What the New Remittance Transfer Excise Tax Means for Businesses

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OVERVIEW OF THE REMITTANCE TRANSFER EXCISE TAX - Do you effect transfers of funds for US residents to recipients abroad? If so, you should review the provision of the “One Big Beautiful Bill Act” (“OBBBA”) that imposes a...more

ASKramer Law

Tax-Loss Harvesting Part II: The Wash Sales Rule

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At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...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

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...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

Allen Matkins

Bonus Depreciation Is Back! And Other Big Beautiful Taxes

Allen Matkins on

On Friday, July 4, 2025, President Trump signed into law the Reconciliation Bill commonly known as the One Big Beautiful Bill Act (OBBBA). Broadly speaking, the OBBBA extends and makes permanent many provisions enacted by the...more

Hanson Bridgett

IRS Clarifies Income Tax Withholding and Reporting Obligations for Uncashed Retirement Checks

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When an employer (or the proper withholding agent, like a plan administrator) issues a retirement benefit, there is generally an obligation to withhold income tax on the payment and to report the payment on Form 1099-R....more

BCLP

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

BCLP on

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

Holland & Knight LLP

A Look at Transfers of Section 1202 Qualified Small Business Stock

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Section 1202 of the Internal Revenue Code provides that noncorporate taxpayers may exclude certain gains on the disposition of Qualified Small Business Stock (QSBS) held longer than the minimum required holding period. One...more

Cozen O'Connor

Tax Provisions Under One Big Beautiful Bill Affecting Real Estate Investment

Cozen O'Connor on

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

McCarter & English, LLP

One Big Beautiful Bill Act Tax Law Updates–Private Educational Institutions and Nonprofits

On July 4, 2025, President Trump signed into law legislation commonly referred to as the “One Big Beautiful Bill Act” (OBBBA), which includes provisions that specifically affect private primary, secondary, and post-secondary...more

Goodwin

Online Filing of Section 83(b) Elections Is Here!

Goodwin on

Last year, the US Internal Revenue Service (IRS) released Form 15620 for taxpayers to make elections under section 83(b) of the Internal Revenue Code, an important part of US tax planning for founders, employees, board...more

Troutman Pepper Locke

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

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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

Eversheds Sutherland (US) LLP

Tax Bytes: Week of July 14, 2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

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