in Light
of OBBBA
such as deductions for qualified small business stock (QSBS), research and experimentation costs, and reduced limitations on business interest deductions. These changes encourage investment and business growth.
Expansion and permanence
of important business tax benefits
affecting U.S. companies with foreign operations, including significant reductions in the number of foreign corporations that are treated as controlled foreign corporations (CFC), and favorable modifications to the pro rata share rules affecting U.S. shareholders in CFC.
Important changes
to international tax rules
impacting businesses involved in renewable energy and energy storage.
Extension and modification
of energy tax incentives
and increased benefits for business owners investing in small businesses, including holding period reductions and elevated exemption limits on capital gains.
Enhanced incentives for Qualified Opportunity Zones
providing high-net-worth business owners with greater estate planning flexibility and wealth transfer opportunities.
Increased estate, gift, and generation-skipping tax exemption amounts
and preservation of workarounds useful for pass-through entities, helping reduce state-level tax burdens for businesses, especially family offices and partnerships.
Modifications to state and local tax (SALT) deduction limits,