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Treasury Signals Increased Scrutiny on QSBS Trust “Stacking” Strategies

Treasury Department officials are discussing their concerns with Qualified Small Business Stock (QSBS) “stacking” strategies. Concerns were raised about stacking at two recent conferences; one official brought it up at the May meeting of the American Bar Association’s Tax Section, and another at a law firm-sponsored conference. Under the QSBS rules, each “taxpayer” is entitled…

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Essential FAQs on 83(b) Election for Non‑U.S. Taxpayers

Receiving equity from a U.S. company if you are not a U.S. citizen or resident alien can raise questions about how and when that equity is taxed in the United States. For U.S. tax purposes, these individuals are generally referred to as “nonresident aliens” or “non-U.S. persons.” One common consideration is whether to file an…

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What Mamdani’s Estate Tax Proposal Could Mean for New York Estate Planning

For many New Yorkers, estate tax planning has felt like something that could wait. Under current law, that reaction is understandable. New York’s basic exclusion amount for 2026 is $7.35 million, which means many families and business owners still feel comfortably outside the state estate tax conversation. That is why the recent proposal linked to…

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IRS Payments: Small Errors That Cause Big Headaches

As the IRS continues shifting toward electronic only payments, taxpayers are gaining convenience — but also facing new pitfalls. Whether you’re making an estimated payment, an extension payment or paying a balance due with a notice, correctly selecting the payment type and tax year is essential to keeping your IRS account accurate and avoiding unnecessary…

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Optimizing Executive Compensation: RSUs, ISOs, NSOs and Deferred Comp 

Equity compensation deferral arrangements can be excellent wealth builders, but each one follows its own tax clock. Knowing when income is recognized—and what rate applies—drives better decisions. From RSUs and incentive stock options (ISOs) to nonqualified stock options (NSOs) and deferred compensation plans, equity compensation comes with distinct tax rules, timing considerations and planning opportunities….

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IRS Issues New Guidance on Crypto Staking and Grantor Trusts

The IRS has released new guidance on crypto staking and grantor trusts that marks a pivotal step for trusts navigating the complexities of digital asset investments. The IRS guidance in Revenue Procedure 2025-31 provides clarity for grantor trusts that hold digital assets. Historically, there were concerns that engaging in staking activities, particularly with proof-of-stake cryptocurrencies,…

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