United States: Income Tax

As public scrutiny and threats against corporate leaders intensify, more companies are investing in comprehensive security packages for senior executives.

Section 1202 of the US tax code offers qualified small business stock (QSBS) holders the ability to exclude significant capital gains from federal income tax, with recent legislation raising the exclusion cap to $15 million per taxpayer for stock acquired after July 4, 2025. Strategic use of properly structured non-grantor trusts can multiply these tax benefits through "trust stacking" while simultaneously achieving substantial estate tax savings. Cross-border families and multinational founders must coordi

July 4, 2026, is not just the 250th anniversary of American independence. It is also the first day contributions can begin flowing into “Trump accounts,” a new category of child investment...

The Tenth Circuit's Liberty Global decision addresses a fundamental question about when the codified economic substance doctrine applies to tax transactions.

Employers continue to receive pitches for wellness and medical indemnity programs promising significant payroll tax savings, but recent IRS guidance makes clear these arrangements...

Federal courts are divided on whether the "limited partner exception" from self-employment tax applies only to passive investors or extends to all partners in limited partnerships with limited liability. With appeals pending in multiple circuits and the Fifth Circuit rejecting the Tax Court's functional analysis approach, the resolution of this controversy will significantly impact fund managers, professional service partnerships, and other passthrough business owners.

Employer-issued recourse promissory notes allow employees to acquire equity without immediate cash outlay, but they create personal liability regardless of stock performance. This analysis examines the strategic advantages, tax implications, and significant risks that both companies and employees face when using this compensation structure.

In this episode of Splitting Heirs, host Warren K. Racusin invites Lowenstein partner Michael N. Gooen and Dr. Paul Hokemeyer, the founding principal of Drayson Mews

While the Seventh Circuit vacated and remanded the Tax Court's decision, it did not reverse it. The Tax Court will have the opportunity to apply the claim of right doctrine and may still conclude that contributions...