The One Big Beautiful Bill Act established a new type of tax deferred savings account for children (the “Trump Account”). The IRS just released detailed guidance in Notice 2025-68 explaining how these accounts work. In simple terms, after tax contributions
It is widely understood that you can defer taxation of the gain on a sale of investment real estate if the sale proceeds are reinvested into new investment real estate within 180 days. This timing can be challenging to meet.
We frequently deal with companies that would like to issue profits interest retroactively. The typical scenario is that the company intended to or agreed to issue profits interests to a service provider and for one reason or another the paperwork
Section 83(b) allows taxpayers to elect to include in their current taxable income certain compensation that would not otherwise be taxable until a future year. For example, a taxpayer that receives restricted stock compensation that would be taxable in future
The One Big Beautiful Bill Act (OBBBA), which made the Opportunity Zone program permanent also established detailed reporting obligations for Qualified Opportunity Funds (QOFs). It also imposes reporting requirements on the Qualified Opportunity Zone Businesses (QOZBs) owned by the QOFs.
The One Big Beautiful Bill Act introduced a powerful new tax benefit for the manufacturing and production industries. Under Internal Revenue Code Section 168(n), businesses can immediately expense 100% of the cost of Qualified Production Property (QPP)—even when it’s real
As discussed in a prior “Did You Know,” pre-closing income tax liabilities have historically not been much concern for the buyer of LLC interests, since the income of LLCs (taxed as partnerships) is not a liability of the target company
The QOZ tax credits were enacted in 2017 and sunset on December 31, 2026. This credit allows taxpayers to defer until December 31, 2026, the taxation of gain that they reinvest in a QOZ. The amount of deferred gain that
Content by Marko Belej with assistance by summer associate Natalie Esshaki
Before the One Big Beautiful Bill was passed, Section 1202 allowed a taxpayer who held QSBS for a minimum of 5 years to exclude 100% of the gain from
Most investors know that Qualified Opportunity Funds (QOFs) offer powerful tax benefits. Taxpayers can defer the tax on the gains that are reinvested in the QOF until the earlier of December 31, 2026 or when they sell the QOF investment.
