QSBS Fundamentals
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Structuring the Ownership of Qualified Small Business Stock (QSBS) – Is There a Role for Roth IRAs?
October 15, 2024 | Publications
This article considers whether there is a role for a self-directed Roth IRA when structuring the own...
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Navigating Section 1202’s Redemption (Anti-churning) Rules
September 30, 2024 | Blogs
Section 1202 provides for a substantial exclusion of gain from federal income taxes when stockholder...
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Dealing with Excess Accumulated Earnings in a Qualified Small Business – A Section 1202 Planning Guide
September 4, 2024 | Publications
This article is one in a series of articles and blogs addressing planning issues relating to qualifi...
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Can Stockholders of Employee Leasing or Staffing Companies Claim Section 1202’s Gain Exclusion?
April 25, 2024 | Blogs
Stockholders must satisfy several eligibility requirements before they can claim Section 1202’s ge...
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Guide to the Federal Income Tax Treatment of SAFEs
April 16, 2024 | Publications
The Simple Agreement for Future Equity (SAFE) was introduced in 2013 on the startup accelerator Y Co...
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How to Use SAFE Preferred Stock in Early Funding Rounds
April 12, 2024 | Blogs
The Simple Agreement for Future Equity (SAFE) was introduced in 2013 by startup accelerator Y Combin...
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A Section 1202 Walkthrough: The Qualified Small Business Stock Gain Exclusion
September 12, 2022 | Qualified Small Business Stock (QSBS)
Section 1202 allows stockholders to claim a minimum $10 million federal income tax gain exclusion in...
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How Section 1202’s $50 Million Aggregate Gross Assets Limitation Works
May 17, 2022 | 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...
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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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The Role of the Business Purpose Doctrine in Transaction Planning Involving Qualified Small Business Stock
September 3, 2021 | Qualified Small Business Stock (QSBS)
This article addresses the importance of having bona fide (non-federal income tax) business and pers...
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New IRS Private Letter Ruling Helps Define the Scope of Proscribed Excluded Activities Under Section 1202
April 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...
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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...