Qualified Small Business Stock (QSBS)
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Part 2 – Reinvesting QSBS Sales Proceeds on a Pre-tax Basis Under Section 1045
April 19, 2022 | Blogs
Section 1045 allows stockholders to reinvest on a pre-tax basis, proceeds from the sale of qualified...
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Selling QSBS Before Satisfying Section 1202’s Five-Year Holding Period Requirement?
April 19, 2022 | Blogs
A stockholder must hold qualified small business stock (QSBS) for more than five years in order to c...
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How Corporations May Run Afoul of the Accumulated Earnings Tax – A Section 1202 Planning Brief
February 16, 2022 | Blogs
We have discussed in previous articles the potential benefits of operating a start-up as a C corpora...
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Section 1202 Planning: When Might the Assignment of Income Doctrine Apply to a Gift of QSBS?
January 26, 2022 | Blogs
Section 1202 allows taxpayers to exclude gain on the sale of QSBS if all eligibility requirements ar...
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Planning for the Potential Reduction in Section 1202’s Gain Exclusion
November 3, 2021 | Blogs
On September 13, 2021, legislation emerged from the House Ways and Means Committee that included an ...
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A SPAC Merger Primer for Holders of Qualified Small Business Stock
September 30, 2021 | Blogs
The number of private companies electing to go public through a transaction (referred to in this art...
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Transfers “At Death” of Qualified Small Business Stock
September 29, 2021 | Blogs
This article addresses the consequences of “transfers at death” of qualified small business stoc...
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Congress Proposes Legislation Limiting Section 1202’s Gain Exclusion
September 16, 2021 | Blogs
When Congress enacted Section 1202, it noted that the gain exclusion was intended to “encourag...
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Claiming an Ordinary Loss Under Section 1244 for an Investment in a Failed Start-up
September 3, 2021 | Blogs
Congress enacted Section 1202[i] based on the premise that the possibility of a $10 million gain exc...
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The Role of the Business Purpose Doctrine in Transaction Planning Involving Qualified Small Business...
September 3, 2021 | Blogs
This article addresses the importance of having bona fide (non-federal income tax) business and pers...
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Transfer Planning With Qualified Small Business Stock
May 21, 2021 | Blogs
During the past several years, there has been a marked increase across the country in the use of C c...
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New IRS Private Letter Ruling Helps Define the Scope of Proscribed Excluded Activities Under Section...
April 15, 2021 | Blogs
During the past several years, there has been a marked increase across the country in the use of C c...