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Renan Rodriguez

Rey advises clients on a variety of transactional matters, including mergers and acquisitions, distribution structures, internal reorganizations, and cross-border transactions. He also assists clients with both inbound and outbound investments involving the U.S., aiming to address the business and tax considerations that arise in these contexts.

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Empty Classroom with Colorful Chairs and Desks school 1
An empty classroom is depicted with rows of wooden desks and chairs in various colors including yellow, blue, and red. Sunlight streams through large windows, illuminating the space and casting shadows. A green blackboard is visible on the wall.

The enactment of Section 25F of the Internal Revenue Code—part of the One Big Beautiful Bill Act (P.L. 119-21)—is one of the most significant developments in education-related tax policy in a generation. Building on decades of state-level tax credit scholarship programs, Congress has established a federal framework that channels private philanthropic capital into K-12 scholarships through a new qualifying vehicle: the Scholarship Granting Organization (“SGO”). For schools, charities, and foundations invested in educational access, the moment calls for informed strategic planning.