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The OBBBA has a significant tax change for founders tucked away inside, lifting the cap to $75 million with many opportunities to turbo-charge business 

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In an era of economic uncertainty and shifting regulations, the One Big Beautiful Bill Act (OBBBA) presents a notable opportunity for entrepreneurs and early-stage investors. Among its provisions is a significant overhaul of the Qualified Small Business Stock (QSBS) rules—changes that could dramatically reshape the financial future for countless founders. 

What’s New with QSBS?

QSBS has long been a valuable tool for founders and investors, allowing them to exclude the greater of $10 million or ten times their cost basis from capital gains tax when selling qualified stock of a domestic C corporation held for more than five years—provided certain conditions are met. The OBBBA enhances this framework by increasing the per-issuer limitation from $10 million to $15 million, indexed for inflation, for QSBS issued after July 4, 2025. 

Even more transformative is the introduction of partial exclusions starting in year three, enabling founders and investors to access the exclusion sooner than ever before. For QSBS issued after July 4, 2025, eligible gains can be excluded on the following scale: 

 This phased approach is particularly significant in today’s fast-paced market, where the ability to pivot and adapt can mean the difference between success and failure. Founders can now plan their exits with greater flexibility, confident in the knowledge that they have options that were previously unavailable. 

A Bigger Cap, a Bigger Opportunity

 Previously, only Domestic C corporations with gross assets under $50 million could issue QSBS. The OBBBA raises that threshold to $75 million, opening the door for more companies to benefit from these tax advantages. This development maybe vital for startups and small businesses that often struggle to attract investment in a competitive landscape. By allowing larger capital influxes while preserving tax benefits, the OBBBA enables founders to scale their businesses more effectively. 

The increased cap not only enhances tax benefits but also unlocks new strategies for capital raising, exit planning, and entity structuring. Companies that once exceeded the $50 million limit but now fall below the revised threshold can resume issuing QSBS until they again surpass the inflation-adjusted cap. This change presents a strategic opportunity for corporations to attract investors and employees, fostering growth. 

Staying Under the Cap: Smart Planning Matters

The OBBBA also includes several provisions that may help corporations reduce the tax basis of their assets, enabling them to remain below the $75 million inflation-adjusted gross asset limitation and continue issuing QSBS longer. For research-heavy businesses, one key change is the immediate expensing of domestic research and experimental costs under Section 174A. Starting in 2025, these expenses will be fully deductible upfront, reducing asset basis and keeping balance sheets leaner. Additionally, the reinstated 100% bonus depreciation will further help companies manage their asset levels and extend their eligibility to issue QSBS longer. 

Choosing the Right Structure: C Corp vs. Pass-Through

While the OBBBA significantly enhances the appeal of QSBS, it’s important to remember that these benefits apply only to stock issued by domestic C corporations. This means founders must carefully weigh the trade-offs between forming a C corporation and opting for a pass-through entity such as an LLC or S corporation. C corporations are subject to double taxation—once at the corporate level on profits, and again when those profits are distributed to shareholders as dividends. In contrast, pass-through entities typically face only a single layer of tax, which can be more efficient in certain scenarios. 

However, many startups don’t distribute profits in their early years, making the double taxation of C corporations less of a concern initially. In fact, the optimal QSBS outcome often involves retaining earnings taxed at the lower corporate rate and later excluding gains upon sale—provided the sale is structured as a stock transaction. This strategy requires thoughtful planning but can result in substantial tax savings for founders and investors. 

A Call to Action for Founders

The QSBS reforms found in the OBBBA are more than just tax tweaks—they’re a strategic invitation for founders to rethink how they grow and raise capital and plan exits. But these benefits won’t materialize automatically. Founders must proactively adapt to the new rules, assess their business structures, and plan with precision. For those who do, the rewards could be substantial. The increased cap, phased exclusions, and expanded eligibility create fertile ground for innovation and growth. In a challenging economic landscape, the OBBBA offers a rare tailwind—one that savvy entrepreneurs can harness to build stronger, more resilient businesses. 

This material has been distributed for informational purposes only. Bernstein does not provide tax, legal, or accounting advice. 

The opinions expressed in Fortune.com commentary pieces are solely the views of their authors and do not necessarily reflect the opinions and beliefs of Fortune.



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Google DeepMind agrees to sweeping partnership with the U.K. government

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AI lab GoogleDeepMind announced a major new partnership with the U.K. government Wednesday, pledging to accelerate breakthroughs in materials science and clean energy, including nuclear fusion, as well as conducting joint research on the societal impacts of AI and on ways to make AI decision-making more interpretable and safer.

As part of the partnership, Google DeepMind said it would open its first automated research laboratory in the U.K. in 2026. That lab will focus on discovering advanced materials including superconductors that can carry electricity with zero resistance. The facility will be fully integrated with Google’s Gemini AI models. Gemini will serve as a kind of scientific brain for the lab, which will also use robotics to synthesize and characterize hundreds of materials per day, significantly accelerating the timeline for transformative discoveries.

The company will also work with the U.K. government and other U.K.-based scientists on trying to make breakthroughs in nuclear fusion, potentially paving the way for cheaper, cleaner energy. Fusion reactions should produce abundant power while producing little to no nuclear waste, but such reactions have proved to be very difficult to sustain or scale up.

Additionally, Google DeepMind is expanding its research alliance with the government-run U.K. AI Security Institute to explore methods for discovering how large language models and other complex neural network-based AI models arrive at decisions. The partnership will also involve joint research into the societal impacts of AI, such as the effect AI deployment is likely to have on the labor market and the impact increased use of AI chatbots may have on mental health.

British Prime Minister Keir Starmer said in a statement that the partnership would “make sure we harness developments in AI for public good so that everyone feels the benefits.”

“That means using AI to tackle everyday challenges like cutting energy bills thanks to cheaper, greener energy and making our public services more efficient so that taxpayers’ money is spent on what matters most to people,” Starmer said.

Google DeepMind cofounder and CEO Demis Hassabis said in a statement that AI has “incredible potential to drive a new era of scientific discovery and improve everyday life.”

As part of the partnership, British scientists will receive priority access to Google DeepMind’s advanced AI tools, including AlphaGenome for DNA sequencing; AlphaEvolve for designing algorithms; DeepMind’s WeatherNext weather forecasting models; and its new AI co-scientist, a multi-agent system that acts as a virtual research collaborator.

DeepMind was founded in London in 2010 and is still headquartered there; it was acquired by Google in 2014.

Gemini’s U.K. footprint expands

The collaboration also includes potential development of AI systems for education and government services. Google DeepMind will explore creating a version of Gemini tailored to England’s national curriculum to help teachers reduce administrative workloads. A pilot program in Northern Ireland showed that Gemini helped save teachers an average of 10 hours per week, according to the U.K. government.

For public services, the U.K. government’s AI Incubator team is trialing Extract, a Gemini-powered tool that converts old planning documents into digital data in 40 seconds, compared to the current two-hour process.

The expanded research partnership with the U.K. AI Security Institute will focus on three areas, the government and DeepMind said: developing techniques to monitor AI systems’ so-called “chain of thought”—the reasoning steps an AI model takes to arrive at an answer; studying the social and emotional impacts of AI systems; and exploring how AI will affect employment.

U.K. AISI currently tests the safety of frontier AI models, including those from Google DeepMind and a number of other AI labs, under voluntary agreements. But the new research collaboration could potentially raise concerns about whether the U.K. AISI will remain objective in its testing of its now-partner’s models.

In response to a question on this from Fortune, William Isaac, principal scientist and director of responsibility at Google DeepMind, did not directly address the issue of how the partnership might affect the U.K. AISI’s objectivity. But he said the new research agreement puts in place “a separate kind of relationship from other points of interaction.” He also said the new partnership was focused on “question on the horizon” rather than present models, and that the researchers would publish the results of their work for anyone to review.

Isaac said there is no financial or commercial exchange as part of the research partnership, with both sides contributing people and research resources.

“We’re excited to announce that we’re going to be deepening our partnership with the U.K. AISI to really focus on exploring, really the frontier research questions that we believe are going to be important for ensuring that we have safe and responsible development,” he said.

He said the partnership will produce publicly accessible research focused on foundational questions—such as how AI impacts jobs or how talking to chatbots effects mental health—rather than policy-specific recommendations, though the findings could influence how businesses and policymakers think about AI and how to regulate it.

“We want the research to be meaningful and provide insights,” Isaac said.

Isaac described the U.K. AISI as “the crown jewel of all of the safety institutes” globally and said deepening the partnership “sends a really strong signal” about the importance of engaging responsibly as AI systems become more widely adopted.

The partnership also includes expanded collaboration on AI-enhanced approaches to cybersecurity. This will include the U.K. government exploring the sue of tools like Big Sleep, an AI agent developed by Google that autonomously hunts for previously unknown “Zero Day” cybersecurity exploits, and CodeMender, another AI agent that can search for and then automatically patch security vulnerabilities in open source software.

British Technology Secretary Liz Kendall is visiting San Francisco this week to further the U.K.-U.S. Tech Prosperity Deal, which was agreed to during U.S. President Trump’s state visit to the U.K. in September. In November alone, the British government said the pact helped secure more than $32.4 billion of private investment committed to the U.K tech sector.

The Google-U.K. partnership builds on a £5 billion ($6.7 billion) investment commitment from Google made earlier this year to support U.K. AI infrastructure and research, and to help modernize government IT systems.

The British government also said collaboration supports its AI Opportunities Action Plan and its £137 million AI for Science Strategy, which aims to position the UK as a global leader in AI-driven research.



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49-year-old Democrat who owns a gourmet olive oil store swipes another historically Republican district from Trump and Republicans

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Democrat Eric Gisler claimed an upset victory Tuesday in a special election in a historically Republican Georgia state House district.

Gisler said he was the winner of the contest, in which he was leading Republican Mack “Dutch” Guest by about 200 votes out of more than 11,000 in final unofficial returns.

Robert Sinners, a spokesperson with the secretary of state’s office, said there could be a few provisional ballots left before the tally is finalized.

“I think we had the right message for the time,” Gisler told The Associated Press in a phone interview. He credited his win to Democratic enthusiasm but also said some Republicans were looking for a change.

“A lot of what I would call traditional conservatives held their nose and voted Republican last year on the promise of low prices and whatever else they were selling,” Gisler said. “But they hadn’t received that.”

Guest did not immediately respond to a text message seeking comment late Tuesday.

Democrats have seen a number of electoral successes in 2025 as the party’s voters have been eager to express dissatisfaction with Republican President Donald Trump.

In Georgia in November, they romped to two blowouts in statewide special elections for the Public Service Commission, unseating two incumbent Republicans in campaigns driven by discontent over rising electricity costs.

Nationwide, Democrats won governor’s races by broad margins in Virginia and New Jersey. On Tuesday a Democrat defeated a Trump-endorsed Republican in the officially nonpartisan race for Miami mayor, becoming the first from his party to win the post in nearly 30 years.

Democrats have also performed strongly in some races they lost, such as a Tennessee U.S. House race last week and a Georgia state Senate race in September.

Republicans remain firmly in control of the Georgia House, but their majority is likely fall to 99-81 when lawmakers return in January. Also Tuesday, voters in a second, heavily Republican district in Atlanta’s northwest suburbs sent Republican Bill Fincher and Democrat Scott Sanders to a Jan. 6 runoff to fill a vacancy created when Rep. Mandi Ballinger died.

The GOP majority is down from 119 Republicans in 2015. It would be the first time the GOP holds fewer than 100 seats in the lower chamber since 2005, when they won control for the first time since Reconstruction.

The race between Gisler and Guest in House District 121 in the Athens area northeast of Atlanta was held to replace Republican Marcus Wiedower, who was in the seat since 2018 but resigned in the middle of this term to focus on business interests.

Most of the district is in Oconee County, a Republican suburb of Athens, reaching into heavily Democratic Athens-Clarke County. Republicans gerrymandered Athens-Clarke to include one strongly Democratic district, parceling out the rest of the county into three seats intended to be Republican.

Gisler ran against Wiedower in 2024, losing 61% to 39%. This year was Guest’s first time running for office.

A Democrat briefly won control of the district in a 2017 special election but lost to Wiedower in 2018.

Gisler, a 49-year-old Watkinsville resident, works for an insurance technology company and owns a gourmet olive oil store. He campaigned on improving health care, increasing affordability and reinvesting Georgia’s surplus funds

Guest is the president of a trucking company and touted his community ties, promising to improve public safety and cut taxes. He was endorsed by Republican Gov. Brian Kemp, an Athens native, and raised far more in campaign contributions than Gisler.



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Rivian CEO says it’s a misconception EVs are politicized, with a 50-50 party split among R1 buyers

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If Rivian’s sales are any indication, owning an electric vehicle isn’t such a partisan issue, despite President Donald Trump’s rollbacks of mandates, incentives, and targets for EVs.

At the Fortune Brainstorm AI conference in San Francisco on Tuesday, Rivian CEO RJ Scaringe said it’s a misconception that electrification is politicized, explaining that most customers buy a product based on how it fits their needs, not their ideology. The questions car buyers ask, he said, are the same whether they’re purchasing one with an internal-combustion engine or a battery: “Is it exciting? Are you attracted to the product? Does it draw you in? Does the brand positioning resonate with you? Do the features answer needs that you have?”

Buyers of Rivian’s R1 electric SUV are split roughly 50-50 between Republicans and Democrats, Scaringe told Fortune’s Andrew Nusca. “I think that’s extraordinarily powerful news for us to recognize—that this isn’t just left-leaning buyers,” he added. “These are people that are saying, ‘I like the idea of this product, I’m excited about it.’ And this is thousands and thousands of customers. This is statistically relevant information.”

Buying an EV was once an indication of left-leaning politics, but the politics got scrambled after Tesla CEO Elon Musk became the top Republican donor and a close adviser to Trump. That drew some new customers to Tesla, and turned off a lot of progressive EV buyers, with many existing owners putting bumper stickers on their Teslas explaining that they bought their cars before Musk’s hard-right turn. Trump and Musk later had a stunning public feud, in part over the administration’s elimination of EV and solar tax credits.

But Scaringe said he started Rivian with a long-term view, independent of any policy framework or political trends. He also insisted that if Americans have more EV choices, sales would follow. Right now, Tesla dominates a key corner of the market, namely EVs in the $50,000 price range. Rivian’s forthcoming R2 mid-size SUV will represent a new choice in that market, with a starting price of $45,000 versus the R1’s $70,000.

Ten years from now, Scaringe said he hopes—and believes—that EV adoption in the U.S. will be meaningfully higher than it is today across the board, explaining that the main constraint isn’t on the demand side. Instead, it’s on the supply side, which suffers from “a shocking lack of choice,” especially compared to Europe and China, he added. EV options in the U.S. are limited by the fact that Chinese brands are shut out of the market.

More choices for U.S. EV buyers would presumably create more competition for Rivian—and indeed, the flood of low-priced Chinese EVs in other auto markets has created a backlash, with countries such as Canada imposing steep tariffs on them. But Scaringe appears to view more competition as positive for the market overall.

“I do think that the existence of choice will help drive more penetration, and it actually creates a unique opportunity in the United States,” he said.



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