United States: Income Tax

Qualified small business stock (QSBS) and non-QSBS issued to founders, employees and independent contractors is generally subject to Section 83.

The Tax Court's recent decision in Continental Grand Limited Partnership v. Commissioner addresses the complex interplay between retroactive entity classification elections and partnership basis calculations. When a German subsidiary retroactively elected to be disregarded as a separate entity before contributing a $610 million promissory note to a U.S. partnership, the court reordered the transaction with significant tax implications. The ruling extends established zero-basis principles to situations...

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

Jennifer D'Amato explores the critical techniques and strategies available under Wisconsin law for post-death estate administration, examining how legal professionals can help families minimize costs, delays, and conflicts during the probate process. The article provides practical guidance on navigating the various administration options available in Wisconsin's aging population landscape.

The IRS has released proposed regulations and draft forms for Trump accounts, new IRA accounts for children that include a $1,000 government-funded pilot program contribution.

Bipartisan legislation aims to reduce compliance burdens on U.S. citizens living abroad by streamlining overlapping international financial reporting requirements and simplifying tax obligations.

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

In this episode of GeTtin' SALTy, podcast host Nikki Dobay welcomes back Representative April Berg of Washington's 44th District for a deep dive into the 2026 landmark 60-day legislative session in Olympia.

This Snippet provides a high-level overview of the recently released Substance-based Tax Incentives Safe Harbour (SBTI SH) and its impact on the Pillar Two (P2) position of multinational groups (MNEs).