Program Details
2026-09-18 13:00:00
Over 1,000+ webinars
Course Overview
2026-09-18 13:00:00
2h CLE Credits
Intermediate
2
1:00 pm - 2:00 pm ESTThis session covers the mechanics and planning considerations for converting LLC and partnership structures into C corporations eligible to issue Qualified Small Business Stock under the post-OBBBA rules effective July 4, 2025. Attorneys will learn the three primary conversion pathways, the FMV basis rule and its effect on gain exclusion calculations, the holding period tacking trap created by the new tiered exclusion regime, and how to satisfy the original issuance, active business, and gross asset requirements. Attendees leave with a working framework for advising clients on pre-conversion structuring, stacking strategies, documentation standards, and state conformity exposure.
Mark A. MeltonBrian M. Balduzzi 2:10 pm - 3:10 pm ESTThis session examines the principal tax structures available when selling a closely held business in the post-OBBBA environment, including asset versus stock deal architecture, personal goodwill planning for C corporation sellers, and earnout characterization. Attorneys will learn how the OBBBA’s permanent restoration of 100% bonus depreciation, the expanded Section 199A deduction, and the raised QSBS exclusion ceiling reshape deal-tax planning for pass-through and corporate sellers alike. Attendees leave with practical frameworks for advising selling owners on structure selection, pre-sale restructuring decisions, and audit-risk mitigation on contested allocations.
Mark A. MeltonBrian M. BalduzziMark A. Melton is a Partner in Holland & Knight’s Dallas office and co-chair of the firm’s Tax, Executive Compensation and Benefits Practice Group. He focuses on federal income taxation issues arising from domestic and international transactions of private equity and hedge funds, investment partnerships, joint ventures, real estate investment trusts, and operating businesses. He assists clients with investment fund formation, mergers and acquisitions, real estate investment and development, and financial instruments and derivatives, and advises on Section 1202 qualified small business stock issues. Before entering private practice, he served as a fund tax manager for a multibillion-dollar international private equity group.
Brian M. Balduzzi is a Partner in Holland & Knight’s Philadelphia and New York offices and a member of the Global Wealth and Family Office Practice Group. He focuses his practice on estate planning, tax planning, charitable planning, business succession, family office services, trust and estate administration, and fiduciary matters for high-net-worth individuals, families, entrepreneurs, executives, fiduciaries, and closely held business owners. His work spans qualified small business stock planning, trust modification and decanting, and advanced vehicles such as spousal lifetime access trusts, intentionally defective grantor trusts, grantor retained annuity trusts, and incomplete non-grantor trusts. Before joining Holland & Knight, he practiced in private client services at an AmLaw 100 firm, where he co-chaired its Family Office Initiative, and held fiduciary strategy roles at a leading trust company advising families with net worth from approximately $25 million to $4 billion.
Mark A. Melton is a Partner in Holland & Knight’s Dallas office and co-chair of the firm’s Tax, Executive Compensation and Benefits Practice Group. He focuses on federal income taxation issues arising from domestic and international transactions of private equity and hedge funds, investment partnerships, joint ventures, real estate investment trusts, and operating businesses. He assists clients with investment fund formation, mergers and acquisitions, real estate investment and development, and financial instruments and derivatives, and advises on Section 1202 qualified small business stock issues. Before entering private practice, he served as a fund tax manager for a multibillion-dollar international private equity group.
Brian M. Balduzzi is a Partner in Holland & Knight’s Philadelphia and New York offices and a member of the Global Wealth and Family Office Practice Group. He focuses his practice on estate planning, tax planning, charitable planning, business succession, family office services, trust and estate administration, and fiduciary matters for high-net-worth individuals, families, entrepreneurs, executives, fiduciaries, and closely held business owners. His work spans qualified small business stock planning, trust modification and decanting, and advanced vehicles such as spousal lifetime access trusts, intentionally defective grantor trusts, grantor retained annuity trusts, and incomplete non-grantor trusts. Before joining Holland & Knight, he practiced in private client services at an AmLaw 100 firm, where he co-chaired its Family Office Initiative, and held fiduciary strategy roles at a leading trust company advising families with net worth from approximately $25 million to $4 billion.
Requirements
The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.
Formats
