Qualified Small Business Stock (QSBS)
-
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...
-
Claiming an Ordinary Loss Under Section 1244 for an Investment in a Failed Start-upSeptember 3, 2021 | Qualified Small Business Stock (QSBS)
Congress enacted Section 1202[i] based on the premise that the possibility of a $10 million gain exc...
-
The Role of the Business Purpose Doctrine in Transaction Planning Involving Qualified Small Business StockSeptember 3, 2021 | Qualified Small Business Stock (QSBS)
This article addresses the importance of having bona fide (non-federal income tax) business and pers...
-
Transfer Planning With Qualified Small Business StockMay 21, 2021 | Qualified Small Business Stock (QSBS)
Section 1202 permits a taxpayer to claim a gain exclusion in connection with the sale or exchange (i...
-
New IRS Private Letter Ruling Helps Define the Scope of Proscribed Excluded Activities Under Section 1202April 15, 2021 | Qualified Small Business Stock (QSBS)
During the past several years, there has been a marked increase across the country in the use of C c...
-
Exploring the Benefits of the Corporate Freeze TransactionMarch 24, 2021 | Qualified Small Business Stock (QSBS)
Synopsis The distribution of a C corporation’s assets to its shareholders often triggers a hea...
-
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...
-
Equity Rollovers in M&A Transactions Involving Section 1202 Qualified Small Business Stock (QSBS)February 19, 2021 | Qualified Small Business Stock (QSBS)
Many M&A transactions are structured to include a rollover of some percentage of the target comp...
-
Rollover Equity Transactions 2021January 28, 2021 | Qualified Small Business Stock (QSBS)
During the 21st century, financial buyers such as private equity sponsors (PE firms) have dramatical...
-
Dealing With the Rollover of the Management Team’s Equity and Equity Rights in a Sale TransactionJanuary 27, 2021 | Qualified Small Business Stock (QSBS)
A typical part of the sale of a business is the rollover of some equity by the target company’...
-
Section 1202 Tax Planning: Avoid Losing the Gain Exclusion!October 26, 2020 | Qualified Small Business Stock (QSBS)
Beware of Mixing Section 1202’s Version of Oil and Water – S Corporations and QSBS Our Section 1...
-
Section 1202 and S CorporationsSeptember 18, 2020 | Qualified Small Business Stock (QSBS)
With the corporate tax rate reduced from 35% to 21%, we have experienced a heightened awareness that...