In the first post in this series, we discussed QSBS and how it can be stacked to optimize tax benefits for founders while being careful not to cross the line into abusing §1202’s allowance for share transfers. That framework is necessary to...

How the One Big Beautiful Bill Act and new §174A reshaped the treatment of research and development spending Almost every company that builds something new spends money to do it: engineers, prototypes, testing, software. For decades, the tax code...

What is QSBS? Qualified Small Business Stock (QSBS) under §1202 of the Internal Revenue Code allows eligible founders, employees, and investors to skip paying federal taxes on capital gains when they sell their stock after holding it for five...

The BDIT and BDOT—Promising Structures, Unsettled Authority, and Practical Risk In the first post in this series, we walked through the underlying income tax problem that trusts create and the three ways the tax law allows you to deal with it. That...

Understanding grantor trusts, compressed tax brackets, and the overlooked power of Section 678 I recently attended the North Texas Probate Bench Bar and had the pleasure of hearing John Hunter of the Blum Firm speak on the 678 Trust. John and I...

What Does This Mean for Limited Partners, LLPs, and LLCs? In Part 1, we covered the U.S. Court of Appeals for the Fifth Circuit’s decision in Sirius Solutions, LLLP v. Commissioner and the Fifth Circuit’s reasoning for siding with taxpayers over...

The Big Picture: Why Sirius Solutions v. Commissioner Matters Let’s cut to the chase: the U.S. Court of Appeals for the Fifth Circuit’s recent decision in Sirius Solutions, LLLP v. Commissioner is a game-changer for anyone who owns a piece of a...

Trusts are designed to protect assets, honor legacies, and provide for loved ones. But what happens when the person entrusted to manage those assets—the trustee—fails to act? Whether it’s ignoring a reimbursement claim, failing to pursue a legal...

In the administration of trusts, trustees are often called upon to make difficult decisions. One of the most consequential, and often overlooked, is the duty to pursue claims on behalf of the trust. Whether those claims involve reimbursement,...

I and others from Shields Legal recently had the privilege of attending the DFW India Chamber of Commerce Annual Awards Banquet—a gathering that was far more than a celebration of business excellence. It was a testament to the enduring ties between...