Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
QSBS Stacking: Leveraging Gifts And Trusts For Additional Section 1202 Exclusions
Section 1202 of the Internal Revenue Code offers substantial tax benefits for qualified small business stock (QSBS) holders, allowing exclusion of gains up to $10 million or more per taxpayer. Strategic gifting of QSBS shares to family members, trusts, and other entities can multiply these exclusions, potentially sheltering tens of millions in capital gains from federal taxation while navigating complex timing, gift tax, and trust structure considerations.
United States Tax
FL
Foley & Lardner
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Article
QSBS Stacking: Leveraging Gifts And Trusts For Additional Section 1202 Exclusions
Section 1202 of the Internal Revenue Code offers substantial tax benefits for qualified small business stock (QSBS) holders, allowing exclusion of gains up to $10 million or more per taxpayer. Strategic gifting of QSBS shares to family members, trusts, and other entities can multiply these exclusions, potentially sheltering tens of millions in capital gains from federal taxation while navigating complex timing, gift tax, and trust structure considerations.
United States Tax
FL
Foley & Lardner
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Article
Property Tax Delinquency And Foreclosure: No Affidavit, No Mercy, Mercy Me
A recent Sixth Circuit decision examines whether property owners are entitled to surplus proceeds when their homes are sold at tax foreclosure auctions for amounts exceeding the underlying tax debt. The case raises fundamental questions about how just compensation should be measured under the Fifth Amendment—specifically whether delinquent taxpayers should receive the fair market value of their property or merely the discounted auction price realized at a forced sale.
United States Real Estate
CW
Cadwalader, Wickersham & Taft LLP
Article
Seller Financing In Washington State
Seller financing offers an alternative path to homeownership for buyers who struggle to meet conventional lending requirements, providing flexibility for both parties while potentially avoiding broker fees. However, these transactions require careful legal documentation including loan agreements, promissory notes, and deeds of trust to prevent adverse consequences. A real estate attorney can guide buyers and sellers through the complexities of seller-financed deals, from drafting paperwork to addressing tit
United States Real Estate
BB
Beresford Booth
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