News & Analysis as of

C-Corporation

Skadden, Arps, Slate, Meagher & Flom LLP

Treasury Proposes Repeal of Controversial Look-Through Rule for Domestically Controlled REITs

On October 21, 2025, the Treasury Department published proposed regulations under the Foreign Investment in Real Property Tax Act (FIRPTA) that would repeal the controversial “look-through” rule adopted in final regulations...more

DLA Piper

Proposed Regulations Repeal Domestic C-Corporation Look-Through Rule for Determination of Domestically Controlled REIT Status

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On October 20, 2025, the United States Department of the Treasury and the Internal Revenue Service issued proposed regulations that modify the rules for determining domestically controlled REIT status. Generally, many non-US...more

Davies Ward Phillips & Vineberg LLP

Proposed regulations restore common market structures for REITs

The Internal Revenue Service (IRS) and U.S. Treasury Department have proposed regulations (the Proposed Regulations) that would expand FIRPTA (Foreign Investment in Real Property Tax Act) relief for domestically controlled...more

Williams Mullen

[Event] 2025 Fall Tax Forum - November 5th, Richmond, VA

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Join Williams Mullen attorneys for our 2025 Fall Tax Forum, where we will dive into key developments shaping the U.S. federal tax landscape following the enactment of the One Big Beautiful Bill Act (the “OBBBA”) this past...more

Paul Hastings LLP

IRS Proposes to Reverse C-Corporation Look-Through Rule for Domestically Controlled REITs

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The Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) treats gain recognized by a foreign person on the disposition of a United States real property interest (USRPI) as income effectively connected with a U.S....more

Mintz - Venture Capital & Emerging Companies...

MintzTech Connect: All Things Technology — October 2025

One of the remarkable things about the US economy is the robust nature of startups and emerging companies. These new enterprises drive growth and create jobs, and in turn fuel additional economic activity, creating a...more

Haynes Boone

Biotech Insights - September 2025

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Qualified Small Business Stock in the Life Sciences Industry - The Internal Revenue Code (“IRC”) § 1202 provides for an exclusion from gain on the sale of qualified small business stock (“QSBS”), up to $15 million (or 10...more

Haynes Boone

Qualified Small Business Stock in the Life Sciences Industry

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The Internal Revenue Code (“IRC”) § 1202 provides for an exclusion from gain on the sale of qualified small business stock (“QSBS”), up to $15 million (or 10 times the stock’s adjusted basis), if certain conditions are met....more

Holland & Knight LLP

The Impact of the One Big Beautiful Bill Act on Family Offices

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President Donald Trump on July 4, 2025, signed into law H.R.1, commonly referred to as the One Big Beautiful Bill Act (OBBB). (For a detailed analysis of the bill, see Holland & Knight's previous alert, "Trump Signs the One...more

Whiteford

Client Alert: Taxable Entity Choice and the Lure of C Corporations

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Before the 2017 Tax Act, owners of a two-or-more-owner business should generally have elected that such business be an LLC taxable as a partnership. After the 2017 Tax Act, that advice remains sound. However, for a business...more

Cole Schotz

Business Formation Considerations for Start-Ups and Emerging Companies

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As corporate attorneys, we come into regular contact with new businesses and have the opportunity to watch as ideas evolve into products, services and creations that better serve society. We also are acutely aware of the...more

Pillsbury - Propel

Asset vs. Equity Deals in M&A: Strategic and Legal Perspectives

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Mergers and acquisitions (M&A) play a pivotal role in driving corporate growth, enabling strategic restructuring, and unlocking ownership value. ...more

Baker Botts L.L.P.

Getting Your Company Ready for a Financing—Building a Solid Foundation for Growth

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Raising capital is a defining moment for any startup, but the groundwork for a successful financing is laid long before you meet your first investor. We’ve seen that the companies best positioned to attract investment are...more

Holland & Knight LLP

Converting from an S Corporation to Qualified Small Business Stock

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The One Big Beautiful Bill Act (OBBB) has spurred even more interest among businesses that may qualify for the tax benefits associated with qualified small business stock (QSBS), including businesses that currently are...more

Rivkin Radler LLP

Gifting Qualified Small Business Stock – Can You “Stack” the Section 1202 Odds In Your Favor?

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C Corp - Imagine a closely held and growing start-up business (“Corp”) that was recently incorporated under state law and, so, is treated as a regular C corporation for purposes of the federal income tax. Thus, Corp will pay...more

Mandelbaum Barrett PC

C-Corp Vs. S-Corp: Key Differences Explained

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Choosing the right corporate structure is one of the first—and most important—decisions a business owner makes. In a recent conversation, Shawn McClelland and Alexa La Barbiera of Mandelbaum Barrett PC’s Corporate Practice...more

Blank Rome LLP

Qualified Small Business Stock in Tax and Estate Planning

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Stock qualifying under Section 1202 of the Internal Revenue Code of 1986, as amended (the “Code”), as Qualified Small Business Stock (“QSBS”) allows eligible non-corporate taxpayers to potentially exclude a portion or all of...more

Tarter Krinsky & Drogin LLP

New Tax Law Increases the Benefits for Qualified Small Business Stock

Benefits Offer Enhanced Tax Exclusions and Eligibility for Founders, Early Employees, and Investors- The recently enacted One Big Beautiful Bill Act makes several taxpayer-friendly revisions to the rules governing Qualified...more

Vicente LLP

How Cannabis Companies Use ESOPs for Tax Savings and Ownership Transition

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What Are ESOPs and Why Do They Matter for Cannabis Operators - Employee Stock Ownership Plans (ESOPs) are federally authorized retirement benefit structures designed to hold company stock in a trust on behalf of employees....more

Greenbaum, Rowe, Smith & Davis LLP

One Big Beautiful Bill Act: An Overview of Impacts on the Tax Code for Business Owners

The One Big Beautiful Bill Act (OBBBA) was signed into law on July 4, 2025. The legislation permanently extends some of the changes to the tax code first introduced in 2018 while adding additional provisions designed to...more

Nelson Mullins Riley & Scarborough LLP

QSBS Gets a Makeover: Key Changes Under the OBBBA

The One Big Beautiful Bill Act (OBBBA) made the following changes to qualified small business stock (QSBS): The holding period is now graduated for stock acquired after July 4, 2025....more

Holland & Knight LLP

Conversion of Partnership and LLC Interests into Qualified Small Business Stock

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Given the recent amendments to Internal Revenue Code Section 1202,1 which increase the benefits of holding qualified small business stock (QSBS), many companies currently operating as tax partnerships may want to convert into...more

WilmerHale

Alternative Structures for Life Sciences Companies: The LLC Holding Company

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Life sciences companies (particularly early stage companies) may be attracted to an LLC holding company structure as an alternative to a typical C corporation structure to maximize both the purchase price paid by a future...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part VI – Corporate Charitable Deductions / A Floor Has Been...

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In this sixth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss a provision of the Act that impacts the deductibility of corporate charitable gifts under Code Section 170(b)(2)(A)....more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part V – Qualified Small Business Stock Exclusion / Code Section...

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In this fifth installment of my multi-part series on the One Big Beautiful Bill Act, Steve Nofziger and I discuss a provision of the Act that impacts certain business owners who are contemplating a sale of their shares, Code...more

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