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Capital Gains

Troutman Pepper Locke

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

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On May 22, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the BBB). The BBB proposes amendments to the Internal Revenue Code (the Code) that could have...more

Miles & Stockbridge P.C.

For Whom the Tax Tolls: Maryland’s Budget Bill and Its Fiscal Effects

Maryland Gov. Wes Moore recently signed the $67 billion state budget for 2026 (HB 352) that will make significant changes to the state’s tax system. Among other changes, the budget bill notably establishes a new tax on IT...more

Kohrman Jackson & Krantz LLP

Navigating Interest Income in 1031 Exchanges: Strategic Considerations for Tax Deferral

As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more

International Lawyers Network

Establishing a Business Entity in Kenya (Updated)

a) Types of business entities in Kenya - Kenya has 5 main types of business entities that is, sole proprietorships, partnerships, limited liability partnerships, companies, non-governmental organizations and trusts. A...more

Cadwalader, Wickersham & Taft LLP

Carried Interest Survives Budget Bill … for Now

On May 15, 2025, the House released the draft FY 2025 budget bill. As currently drafted, the budget bill does not limit or otherwise change the tax treatment of carried interest.  Following the release of the budget bill,...more

Hinckley Allen

Qualified Small Business Stock: Pre-Acquisition Planning for Tax Savings Upon Exit

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Issuing qualified small business stock (“QSBS”) is a valuable tool that can provide significant tax savings to searchers and independent sponsors alike upon the eventual sale of one or more of their portfolio companies....more

Kohrman Jackson & Krantz LLP

Combining Membership Interest Purchase Agreements & 1031 Exchanges to Maximize Tax Efficiency in Real Estate Deals

The intersection of real estate transactions and tax strategy has long been a focal point for investors seeking to optimize returns while minimizing liabilities. Two powerful tools in this arena – the Membership Interest...more

Morgan Lewis

Federal Fiscal Court on Trade Tax for Commercially Infected Upper-Tier Partnerships - Legal Insights Germany

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The German Federal Fiscal Court (BFH) confirmed its case law according to which the commercial infection of an upper-tier partnership pursuant to Section 15 para. 3 no. 1 sentence 1 alt. 2 German Income Tax Code...more

Rosenberg Martin Greenberg LLP

Will Maryland Provide Value in Exchange for 2026 Tax Increases?

Maryland Governor Wes Moore is expected to sign (if he has not by the date of this publication) House Bill 0350 in the coming weeks. The final version of the bill includes several major tax increases to address budget...more

Blank Rome LLP

Cannabis ESOPs Provide Solutions for Operators

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As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...more

Cadwalader, Wickersham & Taft LLP

Tax Court Calls Bluff on Hedge Fund’s Basket Option Contracts

The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more

Rivkin Radler LLP

State Taxation of a Nonresident’s Gain from the Sale of Stock –The Shot Heard Round the Country?

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Last month, Bloomberg carried an article about a “small but growing trend” of states that are either cutting their individual income taxes or phasing them out entirely. According to the article, the states adopting these...more

Kohrman Jackson & Krantz LLP

QSBS Capital Gains Exclusions: Utilize Estate Planning to Maximize Benefits

Qualified Small Business Stock (QSBS) offers business owners significant federal tax benefits of exclusion of up to $10 million or ten times the stock’s basis in capital gains, whichever is greater. The stock must be held for...more

Conn Kavanaugh

Alimony Refresher

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Enactment of the “Alimony Reform Act” The “Alimony Reform Act” of Massachusetts (G. L. c. 208, §§ 48- 55) was enacted in 2012 and dramatically altered the spousal support/alimony landscape. Thirteen years later, it is...more

Blank Rome LLP

Massachusetts Court Subjects Nonresident to Income Tax on Gain from Stock Sale

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In a decision with troubling potential implications, a Massachusetts appellate court held that a nonresident individual was subject to Commonwealth income tax on capital gain from the sale of his stock in the corporation that...more

Farrell Fritz, P.C.

M&A Tax Concepts: What is a “Gross-up Payment,” and Why Does It Matter?

Farrell Fritz, P.C. on

Buying or selling a business is an exciting experience, and potentially lucrative opportunity for all parties. Most often, during the letter of intent / early negotiations phase, a “deal” is struck based primarily on economic...more

Holland & Knight LLP

The Tax and Trade Outlook from Washington, D.C., for Equine Businesses

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As Congress shifts into gear on the budget reconciliation process and tax day approaches, there are several key issues for horse owners to keep in mind. In the 119th Congress, there are two proposals that have been...more

Adler Pollock & Sheehan P.C.

What’s My Collection Worth? Proper Estate Planning is Important When Accounting for Works of Art

If you possess paintings, sculptures or other art pieces, they may represent a significant portion of your estate. Thus, these assets must be properly accounted for in your estate plan....more

Goulston & Storrs PC

Massachusetts Targets Founder’s Share Sale After Move…To New Hampshire

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The Massachusetts Court of Appeals has ruled that, in some situations, a former resident of the Commonwealth can be liable for Massachusetts income tax on the sale of shares in a Massachusetts-headquartered company even after...more

DarrowEverett LLP

Massachusetts Court Decision Could Spark State Tax Crackdown Nationwide

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Founders and executives with equity compensation need to be prepared for state tax exposure, even in states where they do not live. In a landmark decision that reverberates beyond Massachusetts, the Massachusetts Appeals...more

Bennett Jones LLP

Quebec Budget 2025-26: Important Changes to Quebec Flow-Through Share Regime and Refundable Tax Credit Regime for Mining and Other...

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The 2025-26 Quebec budget, released on March 25, 2025, includes important (and adverse) changes to the deductions and exemptions available under the Quebec flow-through share regime, removing many of the additional provincial...more

Mayer Brown

Conséquences fiscales de la conclusion d'un protocole transactionnel conclu postérieurement à la cession de titres sur...

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La Cour administrative d'appel de Nancy confirme que la plus-value réalisée lors d'une cession de titres est imposable au titre de l'année au cours de laquelle l'opération intervient et que le paiement effectif du prix est...more

Mayer Brown

L'erreur comptable délibérée et l'inscription en comptabilité de titres de participation

Mayer Brown on

Dans une décision du 12 mars 2025, le Conseil d'Etat confirme que si l'inscription initiale de titres en titres de participation constitue une erreur délibérée, la société ne peut bénéficier des effets d'une rectification de...more

Hogan Lovells

The French Finance Act for 2025 reforms the tax and social security regime of management packages and amends the regime applicable...

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The French Finance Act for 2025 radically overhauled the tax and social security treatment of management packages. The BSPCE regime is also subject to some amendments. Key changes and features you need to be aware of: a...more

DarrowEverett LLP

Opportunity Zones: Key Deadlines, Tax Benefits, and What’s Next for Investors

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Practitioners, operators and investors in the commercial real estate space are well familiar with Opportunity Zones and how they can be utilized for preferential tax treatment on investments. First created under the 2017 Tax...more

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