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Summary of Proposed Section 899 of the US Internal Revenue Code and Its Impact on Section 892 Benefits and Tax Treaties

Proposed Section 899, introduced as part of the “Defending American Jobs and Investment Act” (H.R. 591) and incorporated into the House Ways and Means Committee’s tax package titled “The One, Big, Beautiful Bill” (the...more

Considering Converting an LLC into a Corporation? Here Are the QSBS Issues You Should Be Thinking About

A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax-related factors that need to be considered, this is often (at least in...more

The Inflation Reduction Act of 2022: Takeaways for the Clean Energy Sector

Inflation Reduction Act Overview - $740 billion package focused on inflation and deficit reduction, health care, and energy security & climate change - • Raises $737 billion in revenue through a new 15% corporate book...more

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