Qualified Small Business Stock (QSBS)
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Congress Proposes Legislation Limiting Section 1202’s Gain ExclusionSeptember 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-upSeptember 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 StockMay 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...
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Exploring the Benefits of the Corporate Freeze TransactionMarch 24, 2021 | Blogs
Synopsis The distribution of a C corporation’s assets to its shareholders often triggers a hea...
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Can Convertible Debt or SAFEs Qualify as QSBS for Section 1202’s Gain Exclusion?February 22, 2021 | Blogs
Only the issuance of “stock” triggers the running of Section 1202’s five-year hold...
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Equity Rollovers in M&A Transactions Involving Section 1202 Qualified Small Business Stock (QSB...February 19, 2021 | Blogs
Many M&A transactions are structured to include a rollover of some percentage of the target comp...
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Rollover Equity Transactions 2021January 28, 2021 | Blogs
During the 21st century, financial buyers such as private equity sponsors (PE firms) have dramatical...
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Dealing With the Rollover of the Management Team’s Equity and Equity Rights in a Sale Transact...January 27, 2021 | Blogs
A typical part of the sale of a business is the rollover of some equity by the target company’...
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Section 1202 Tax Planning: Avoid Losing the Gain Exclusion!October 26, 2020 | Blogs
Beware of Mixing Section 1202’s Version of Oil and Water – S Corporations and QSBS Our Section 1...
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Section 1202 and S CorporationsSeptember 18, 2020 | Blogs
With the corporate tax rate reduced from 35% to 21%, we have experienced a heightened awareness that...