United States: Capital Gains Tax

Washington State has enacted a new 9.9% income tax on individual earnings exceeding $1 million annually, effective January 2028.

Employer-issued recourse promissory notes allow employees to acquire equity without immediate cash outlay, but they create personal liability regardless of stock performance. This analysis examines the strategic advantages, tax implications, and significant risks that both companies and employees face when using this compensation structure.

The IRS has issued final regulations under Treasury Decision 10048 that fundamentally restructure the reporting timeline for partnerships when a partner sells their interest, eliminating a January 31 deadline that practitioners found...

It is important to consider that gifts made within three years of a decedent’s death are “clawed back” into a decedent’s New York taxable estate.

As the U.S. grapples with a multi layered housing crisis, the need for states to act strategically and mobilize public, private and civic...

F-reorganizations offer significant tax and transactional benefits for private equity add-on acquisitions, but they require precise execution. This analysis examines the technical requirements, timing considerations, and regulatory filings necessary to successfully complete these pre-closing reorganizations while protecting both buyers and sellers from historical S-corporation compliance risks.

Earlier today I had the honor and pleasure of hosting Emily Lavery from Fulcrum Public Affairs and Catherine Lyons from the Economic Innovation Group on our quarterly webinar series "From the Land of OZ" where we focus on all things OZ related.

Section 1045 allows taxpayers to elect to roll over proceeds from the sale of qualified small business stock ("QSBS")...

Family offices enter 2026 amid structural changes across tax policy, fiduciary law, and regulatory administration. The One Big Beautiful Bill Act (OBBBA or OB3)...