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July 21, 2025 36 mins

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 6 

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Austin C. Carlson, JD, CPA, Partner at Gray Reed. As a business lawyer and CPA, Austin brings a unique and rare set of skills and perspectives to every area of his practice, which includes corporate and tax counsel on M&A deals, complex corporate and tax planning for domestic and international transactions, foreign account and income disclosure and penalty abatement issues including the Streamlined Filing Compliance Procedures and Delinquent International Information Return Submission Procedures. Tune in to hear Austin and Mishkin discuss key provisions of the One Big Beautiful Bill Act (OB3) that was recently signed into law by President Trump. 

 

Tune in for these key takeaways: 

  • A comprehensive review of the Qualified Opportunity Zone (QOZ) Rules introduced under the 2017 Tax Cuts and Jobs Act (TCJA) 
  • A discussion of the continuation and modification of the QOZ Rules under OB3 
  • Potential tax planning strategies and special opportunities for taxpayers under the modified QOZ Rules 
  • A comprehensive review of the Bonus Depreciation rules under TCJA  
  • A discussion of the continuation and modification of the Bonus Depreciation Rules under OB3 
  • Potential tax planning strategies related to the Bonus Depreciation Rules for domestic and foreign businesses looking to create or onshore business entities in the United States 
  • A comprehensive review of the Qualified Small Business Stock (QSBS) Rules under TCJA 
  • A discussion of the continuation and modification of the QSBS Rules under OB3 
  • Potential tax planning strategies for United States C-Corporations under the QSBS Rules for 2025 and beyond 
  • A discussion related to tax liability insurance and how this may be utilized for uncertain tax positions related to QSBS  

 

Learn more about Austin C. Carlson: 

 

Further Resources: 


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