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Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...more
In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more
In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. Among the proposed changes included in the “American Families Plan” was the increase of the tax rate that...more
IRS defines an S-Corp as a corporation whose shareholders make the election to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes. The owners of an S-Corp report the...more
After the passage of Public Law No. 115-97, formerly known as the Tax Cuts and Jobs Act (the “Tax Reform Act”), U.S. individual shareholders of controlled foreign corporations (“CFCs”) were faced with a difficult decision. ...more
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
The Tax Cuts and Jobs Act of 2017 changes the income tax planning for all businesses, including for small business owners. It is now more important than ever for business owners to consult with their tax advisors before...more
The Sunshine State is one of the lowest tax burden states in the US. Florida has no state individual income tax. At the state level, there is NO tax on social security benefits, retirement income, IRAs, 401(k) accounts,...more
Late in 2017, the Tax Cuts and Jobs Act was passed. It will take effect in 2018. The Tax Cuts and Jobs Act eliminated or limited a number of different tax preference items...more
With the passage of Public Law no. 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act), attorneys in Perkins Coie’s Trust & Estate Planning practice, along with our clients running closely...more
On September 27, 2017, the Secretary of the Treasury, the Director of the National Economic Council, the Chair of the U.S. House Ways and Means Committee, the Chair of the U.S. Senate Finance Committee, the Speaker of the...more
There is a long list of reforms that the Trump administration intends to tackle and one of the items on the list is tax reform. Although there are multiple proposals by various players and significant variations among the...more