The Permanent Challenge of 280E Section 280E can create effective tax rates exceeding 70% for cannabis businesses, fundamentally altering the economics of an otherwise profitable industry. Originally enacted in 1982 after Edmondson v. Commissioner allowed a cocaine trafficker to deduct business expenses, the statute now applies to every state-legal cannabis operation. IRS audit data has […]

Equity compensation represents one of the most overlooked value levers in company building. For growth-stage companies with multi-state teams and approaching liquidity events, the difference between strategic design and template documentation can mean millions in preserved net operating losses (NOLs) at exit, 30% more value delivered to key employees, and months saved during diligence. Quick […]

Life sciences companies navigate a unique gauntlet. Programs pivot, trials fail, and financing windows slam shut without warning. Yet tax decisions made in the scramble of formation echo through every funding round until they crystallize at exit, for better or worse. The One Big Beautiful Bill Act didn’t just adjust rates. It rewired fundamental incentives […]

QSBS in the Post-OBBBA Environment: Understanding the Enhanced Benefits Most startup exits fall squarely in QSBS territory, yet founders routinely forfeit millions in tax savings through early missteps. The difference between proper QSBS planning and hoping for the best? Often $3-5 million on a typical exit. The Qualified Small Business Stock exclusion can now shield […]

For growing companies operating across state lines, multistate tax compliance has always been complex. But 2025 marks a fundamental shift in how states approach enforcement—one that many CFOs and tax directors are discovering too late. While most focus on obvious triggers like economic nexus thresholds and sales tax registration, the often-overlooked coordination between income and […]

For multinational businesses navigating global expansion, the OBBBA introduces changes that go beyond typical rate adjustments. It rewrites fundamental assumptions about where to locate operations, how to structure intellectual property, and when to recognize cross-border income. The Act even renames key international provisions to reflect their evolved nature: Global Intangible Low-Taxed Income (GILTI) becomes “Net […]

P.L. 86-272: A Shrinking Shield In 1959, Congress enacted Public Law 86-272 in response to state efforts to tax out-of-state businesses based on minimal connections. The law established a critical safe harbor: states cannot impose net income taxes on businesses whose only in-state activities involve soliciting orders for tangible personal property, provided those orders are approved […]

Under the Tax Cuts and Jobs Act (TCJA), deductions for investment-related expenses under Section 212 were severely limited, effectively eliminating deductibility for family offices that operate as passive investment vehicles. This change has persisted, and the OBBBA permanently extends the suspension of miscellaneous itemized deductions under Section 67(g), making the Section 212 ban permanent.  That […]