K.C. Chiang and Aime Salazar Publish Article in Tax Notes on Transaction and Structuring Considerations Under the OBBBA

Olshan tax partner K.C. Chiang and associate Aime Salazar published an article in Tax Notes (subscription required) entitled “Transaction and Structuring Considerations Under the OBBBA.” In the article, K.C. and Aime call attention to the major tax changes as a result of the enactment of the One Beautiful Bill Act (“OBBBA”). They note that one interesting development under OBBBA affecting business exit structures is the interaction between the SALT deduction cap and the pass-through entity tax (PTET) election as the SALT deduction cap workaround. Other changes under OBBBA discussed in their article include the expanded tax benefits and opportunities for existing holders and new investors of qualified small business stock (QSBS); the complications surrounding sale bonuses payable out of the purchase price; the limitations for itemized deductions; and the deduction limitation on “excess business losses.”