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Private Ruling Endorses Taxpayer-Friendly Reading of “Qualified Small Business” Under Section 1202

On September 5, 2014, the Internal Revenue Service (“IRS”) released Private Letter Ruling 201436001 (the “Ruling”), which found that a company providing products and services primarily within the pharmaceutical industry was a...more

Recently Proposed Treasury Regulations Regarding the Allocation of Partnership Recourse and Nonrecourse Liabilities Contain...

On January 29, 2014, the Internal Revenue Service (“IRS”) and the Treasury Department issued proposed regulations (the “Proposed Regulations”) modifying the rules under Section 752 regarding the allocation of recourse and...more

Recent Changes Allow Tax-Free Receipt of up to $10 Million in Gain from the Sale of Small Business Stock

One silver lining to the American Taxpayer Relief Act of 2012 (“ATRA”) is that it extended the 100% exclusion for capital gain on qualified small business stock (“QSBS”) acquired between 2010 and 2011 to include stock...more

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