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,