Tax

This alert explains the new process for electronically submitting IRS Form 15620 through the IRS website and provides a background on the Section 83(b) election.

On June 30, 2025, New Jersey enacted legislation adopting the federal QSBS exclusion. In this update we provide an overview of the new law.

The final One Big Beautiful Bill Act expanded the benefits of the Section 1202 “qualified small business stock” rules. This alert discusses these new benefits and their implications. 

A high-level summary of key tax provisions contained in the One Big Beautiful Bill Act that was signed into law by President Trump on July 4, 2025.

A high-level summary of key differences between the House and Senate versions of the One Big Beautiful Bill Act.

The Senate Finance Committee has released its own version of proposed legislation following the House’s passage of the One Big Beautiful Bill Act. In this alert we provide a summary of the proposed changes and their implications.

Proposed Section 899 of the Internal Revenue Code, incorporated into “The One, Big, Beautiful Bill,” aims to impose retaliatory tax measures against certain “applicable persons” from “discriminatory foreign countries.”

President Trump’s legislative priorities advance through Ways and Means, seeking to permanently extend numerous tax cuts and to roll back Biden-era energy tax credits. But looming disagreements among House and Senate Republicans suggest the negotiation process has just begun.

In a historic election, given the backdrop of rising tensions between Canada and the US, Canadians elected Mark Carney and his Liberal party on April 28, 2025. Although the platform released by the Liberals (the Liberal Platform) was light on personal and corporate tax proposals, it did contain several tax policies that focus on innovation and emerging industries.

With the Canadian federal election just under two weeks away, the two major parties leading the current polls, the Liberals (led by Mark Carney) and the Conservatives (led by Pierre Poilievre), have yet to formally release their platforms. However, both have previewed elements of their proposed tax policies.

In this alert, we discuss changes to the scientific R&D tax incentive program proposed to come into force this month and the implications for Canadian innovators. 

Read about the steps to implement a pre-transaction reorganization under Section 368(a)(1)(F), known as an F reorganization, on a target that is treated as an S corporation for tax purposes, which can offer significant tax benefits to buyers and sellers.

This article provides a checklist of action items for foreign companies making an initial expansion into the US, covering essential topics like choosing a business structure, navigating laws and regulations concerning immigration, employment, and taxes, and securing funding.

Read about key tax policy proposals put forth by presidential candidates  Donald Trump and Kamala Harris and what to expect on Capitol Hill from key leaders on tax policy in the 119th Congress in the latest edition of our 2024 Pre-Election Analysis series on how the November 2024 election will impact the legislative and regulatory landscape.

Read about President Biden’s recent withdrawal from the 2024 presidential election and his endorsement of Vice President Kamala Harris as the Democratic nominee, including her stance on technology, climate change, health care, and tax policy.

Draft legislation released on June 10, 2024, which concerns the implementation of Canada’s 2024 federal budget, does not extend capital gains tax relief to corporations, and it subjects private and public stock options to a higher tax rate.

Read about proposed Treasury regulations that provide guidance on the application of the stock buyback excise tax to redemptions and M&A transactions.

The highly anticipated guidance for the second round of allocations (Round Two) under the US Treasury’s §48C Qualifying Advanced Energy Project Tax Credit program was released this week pursuant to IRS Notice 2024-36, with concept papers due potentially in the next 45 days.[1] That doesn’t provide applicants much time, but those with eligible projects should strongly consider submitting a concept paper. Submission of a concept paper is required to submit a full application, and receiving a letter of discouragement from the Department of Energy (DOE) on a concept paper does not preclude an applicant from submitting a full application. Moreover, an applicant that applied for but failed to receive an allocation in the first round is not precluded from applying for an allocation in Round Two.

Canada’s 2024 federal budget, which takes effect on June 25, includes a capital gains inclusion rate increase that will also significantly affect the taxation of stock options. Option holders will get a 50% deduction for the first $250,000 in stock option employment gains and then 33 1/3% after — instead of a 50% deduction across the board.