Tax Law and International Tax Law

Selling an S corporation involves complex tax and legal considerations that can significantly impact after-tax proceeds. This comprehensive analysis examines stock sales versus asset sales, IRC Section 338(h)(10) elections, F reorganizations, and other transaction structures, revealing how different approaches affect both sellers and buyers through detailed tax modeling and strategic planning insights.

The One Big Beautiful Bill Act (OBBBA) has reshaped tax incentives for wineries, expanding opportunities for R&D expense deductions, production property depreciation, and energy credits. Understanding how these changes interact with winery operations—from fermentation systems to facility upgrades—can significantly impact cash flow and investment returns. This framework helps wineries align tax planning with operational decisions to maximize available benefits.

State and local tax (SALT) planning is entering a new phase of complexity. According to the BDO Tax Strategist Survey, over half of all audits and disputes stem from SALT issues. That's no surprise — state rules evolve rapidly...

The One Big Beautiful Bill Act (OBBBA) introduced a new federal income tax deduction for certain overtime compensation for tax years 2025 through 2028.

California Assembly Bill 1790 proposes to repeal the state's Water's Edge election for corporate income tax purposes, a move driven by budget pressures and union advocacy that could fundamentally reshape...

A revised bipartisan crypto tax bill introduces significant changes to how cryptocurrency transactions are taxed, including new rules for staking rewards deferral and stablecoin basis calculations. The legislation proposes different treatment for proof-of-stake versus proof-of-work validation methods, while establishing a 99-cent basis threshold for regulated payment stablecoins pegged to the U.S. dollar.

Massachusetts quietly amended its estate tax statute last summer. This amendment significantly changes how the tax is calculated for non-resident decedents owning Massachusetts real estate.

With a federal estate tax rate of 40%, estate planning conversations often start and stop with the relatively high federal exemption (currently $15 million for individuals and $30 million for married couples).

A revocable living trust (sometimes called a revocable inter vivos trust) is a legal arrangement you create during your lifetime to hold legal title to your assets.

Many founders make tax decisions that affect their exit from the business long before a buyer appears, when they’re still privately held and focused on growth rather than liquidity.

The Treasury Department has significantly shifted its approach to corporate and partnership tax regulation in 2025, withdrawing several proposed rules that faced criticism for being overly burdensome and complex. This regulatory rollback, driven by executive orders aimed at reducing compliance costs, has left taxpayers and advisors navigating uncertainty about which transaction structures remain permissible and how the IRS will enforce substantive tax rules without mandatory reporting requirements.

Asset versus stock purchase structures create fundamentally different tax, liability, and operational outcomes in M&A transactions. Understanding how deal structure affects basis step-up, successor liability exposure, contract assignment requirements, and after-tax proceeds is essential for Oklahoma buyers and sellers navigating acquisitions in 2026, particularly following the OBBBA tax law changes that reshaped QSBS treatment and capital gains planning.