Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More
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
Thinking about investing in a young, promising company? Section 1202 of the tax code offers a significant incentive for individuals to do just that....more
Section 1202 provides a significant incentive for taxpayers to invest in small businesses structured as C corporations by allowing them to exclude large amounts of gain on a future sale of stock in those businesses. ...more
Most founders are familiar with Section 1202 of the Internal Revenue Code, which provides a tax exemption for the sale of Qualified Small Business Stock (QSBS). Less well known is Section 1202's cousin, Section 1045, which...more
Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more
A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax-related factors that need to be considered, this is often (at least in...more
In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more
In light of the banking crisis of 2023, many emerging growth and start-up companies have explored alternative cash management strategies, including holding cash in money market funds or investing in cash equivalents such as...more
On May 12, 2023, the Internal Revenue Service (IRS) published private letter ruling 202319013 (the PLR), which concluded that an enterprise cloud application software company is engaged in a qualified trade or business for...more
In the wake of Silicon Valley Bank’s failure earlier this month, many technology companies are re-examining their treasury management programs and are considering moving cash into a variety of non-demand-deposit instruments,...more
Thaw out with McDermott’s Tax and Private Client teams during our first (of many) Boston Private Client Roundtables where attendees can reconnect with peers in the tax, private client and wealth advisory space in the city. We...more
Are your shareholders leaving money on the table? Certain tax planning strategies, much like magic spells in the Wizarding World of Harry Potter, require some pre-ordained incantations in order to bring them to life. The...more
The exclusion for gain on qualified small business stock (QSBS) under Section 1202 has garnered increasing attention in recent years. With little administrative guidance from the Internal Revenue Service, investors and owners...more
Henry Hobson is a widowed blowhard who fancies himself superior to everyone because he owns a shoe business. Hobson’s daughter Maggie actually runs the business, but Hobson does not pay her....more
Estate planning strategies for founders are typically focused on saving both income taxes and estate taxes. Income tax savings can be achieved by creating and funding multiple trusts with company stock that duplicate any...more
Section 1202 of the Internal Revenue Code provides savvy business founders and investors an opportunity for large tax savings. In fact, if the entity and the business exit are structured correctly, upon an exit, the founders...more
Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more
Join the Williams Mullen Private Client and Fiduciary Services team for our annual Fiduciary Focus event. This year’s agenda is packed with insights on recent developments affecting fiduciaries – including tax law updates...more
A brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Medical Software Deemed a Qualifying Trade for Qualified Small Business Stock Gain Exclusion When certain criteria are met,...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
Plan focuses on eliminating certain available estate planning opportunities and increasing rates for corporations and high net worth individuals. The proposed tax plan from House Ways and Means Committee seeks to eliminate...more
Congress has other plans for tax practitioners this fall, starting with the House Ways and Means Committee’s initial draft of major tax legislation. The draft legislation proposes far-reaching changes to existing tax laws,...more
Proposal’s Effect Would Limit Access to Capital for Small Businesses - An overlooked provision of the new, sweeping tax bill currently under consideration by Congress as part of President Joe Biden’s $3.5 trillion...more
With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more
Please join us for the Winter Tax Forum to be held virtually on Wednesday, January 27, 2021. ...join Anna Derewenda, Jenny Connors, Farhad Aghdami, and Kyle Wingfield for our virtual tax forum where they will cover recent...more