Michael Novogradac, Novogradac & Company LLP
Richard Nugent, Morrison & Foerster LLP
The One Big Beautiful Bill Act supercharged two of the Code's marquee capital-gains incentives—expanding Section 1202 with a tiered exclusion, a $15 million cap, and a $75 million gross-asset ceiling, while making Opportunity Zones permanent and layering in decennial zone redesignations and enhanced rural benefits, including a 30 percent basis step-up. This panel will unpack the new mechanics and the planning traps in each regime—dual-track QSBS rules keyed to July 4, 2025, the 28-percent rate on non-excluded gain, expiring TCJA deferrals, and the shift to the 2027 zone map—and hopes to discuss the first meaningful Section 1202 guidance in a generation, which is expected to address the so-called "stacking" techniques that multiply the exclusion across trusts and family members.