The potential broad applicability of recent guidance addressing situations in which a shareholder’s stock has split holding periods and split basis continues to alarm practitioners, in part because of anomalies in the cross-border context. The IRS has cautioned practitioners against thinking that a May 2020 generic legal advice memorandum (AM 2020-005) applies narrowly or applies too broadly, leaving some pondering the meaning of specific language.
A&M's Kevin M. Jacobs shares his perspective with Tax Notes.
READ THE FULL ARTICLE HERE.
OBBBA and Qualified Small Business Stock: Bigger, Faster, Broader Section 1202 Benefits for PE, VC and Founders
December 4, 2025
Discover how the One Big Beautiful Bill Act (OBBBA) modernizes Section 1202 QSBS, offering earlier exclusions, higher caps, and broader eligibility for PE, VC, and founders.
Final Buyback Regs Are Good News for M&A Transactions, Too
December 4, 2025
The IRS and Treasury abandoned the embattled “funding rule” in final regulations implementing the 1 percent excise tax on stock buybacks and made welcome changes for reorganizations and preferred stock, tax advisers said.
Non-Executive Director Fees in the FTSE All-Share 2025
December 2, 2025
This year’s Non-Executive Director fees report provides a detailed breakdown of all types of NED fees, as well as our thoughts on recent changes to the regulatory backdrop to NED fees in the UK-listed market.
Treasury Redeems Complex Proposed Excise Tax Regulations
December 2, 2025
The Final Regulations governing 1% excise tax on corporate stock repurchases enacted by the Inflation Reduction Act of 2022 were released on November 21, 2025 by Treasury and the IRS.
