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Qualified Small Business Stock Internal Revenue Code (IRC)

Pillsbury - Propel

Estate Planning for Founders - Part II: Planning with Qualified Small Business Stock

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This is the second of a four-part series focusing on estate planning fundamentals for founders. This article will address an important topic for owners of Qualified Small Business Stock (QSBS) as defined in Section 1202 of...more

DarrowEverett LLP

Maximizing QSBS Benefits with Estate Planning: The Art of Stacking

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The number of taxpayers seeking the benefits of Qualified Small Business Stock (“QSBS”) has picked up steam in recent years, particularly since the Tax Cuts and Jobs Act (“TCJA”) lowered the federal corporate tax rates to...more

DarrowEverett LLP

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

DarrowEverett LLP on

Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...more

Pillsbury - Propel

How This Multimillion-Dollar Tax Benefit Can Slip Through Your Fingers: Don’t Miss Out!

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The Qualified Small Business Stock (QSBS) status under Section 1202 of the Internal Revenue Code provides a significant tax advantage for small business owners (i.e., Founders) and investors. It allows for a 100% capital gain...more

Patterson Belknap Webb & Tyler LLP

QSBS Rollovers

Most founders are familiar with Section 1202 of the Internal Revenue Code, which provides a tax exemption for the sale of Qualified Small Business Stock (QSBS).  Less well known is Section 1202's cousin, Section 1045, which...more

Pillsbury Winthrop Shaw Pittman LLP

Estate and Tax Planning 2023 Update: Act While You Can

Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more

Mintz - Tax Viewpoints

Considering Converting an LLC into a Corporation? Here Are the QSBS Issues You Should Be Thinking About

A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax-related factors that need to be considered, this is often (at least in...more

WilmerHale

State Taxation of Qualified Small Business Stock: Federal Tax Exclusion Not Always Replicated at State Level

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In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more

Goodwin

Current Issues for Qualified Small Business Stock - How New R&E Expensing Rules Could Hurt Your QSBS Status, and Why Cash...

Goodwin on

An early-stage company can offer prospective investors an attractive investment opportunity, particularly if the company’s stock will qualify as “qualified small business stock” (QSBS) for US federal income tax purposes. This...more

Wilson Sonsini Goodrich & Rosati

IRS Rules That an Enterprise Cloud Application Software Company Is Engaged in a Qualified Trade or Business for QSBS Purposes

On May 12, 2023, the Internal Revenue Service (IRS) published private letter ruling 202319013 (the PLR), which concluded that an enterprise cloud application software company is engaged in a qualified trade or business for...more

Foley & Lardner LLP

Basics of QSBS and its Application to the Energy Sector

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One of the lesser-known yet very beneficial provisions of the Internal Revenue Code (the Code) relating to business investment is Section 1202. Originally passed in 1993 and amended several times over the years, Section 1202...more

Greenberg Glusker LLP

Harry Potter and the Chamber of Secret QSBS Exclusions

Greenberg Glusker LLP on

Are your shareholders leaving money on the table? Certain tax planning strategies, much like magic spells in the Wizarding World of Harry Potter, require some pre-ordained incantations in order to bring them to life. The...more

Keating Muething & Klekamp PLL

Two New Private Letter Rulings Inform Code Section 1202's Qualified Trade or Business Analysis

Section 1202 of the Internal Revenue Code provides savvy business founders and investors an opportunity for large tax savings. In fact, if the entity and the business exit are structured correctly, upon an exit, the founders...more

Freeman Law

Qualified Small Business Stock: One of the Code’s Most Significant (And Often Overlooked) Tax Breaks

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Section 1202 offers a once little-known exclusion from income for gain on qualified small business stock (“QSB stock”). The provision has undergone substantial revisions over the years and came back into vogue as a result of...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

ArentFox Schiff

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

ArentFox Schiff on

The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

Wyrick Robbins Yates & Ponton LLP

Are My Taxes Going Up? Seven Proposals to Watch from the House Ways and Means Committee’s Draft Tax Legislation

Congress has other plans for tax practitioners this fall, starting with the House Ways and Means Committee’s initial draft of major tax legislation.  The draft legislation proposes far-reaching changes to existing tax laws,...more

Gould + Ratner LLP

New Tax Bill Puts a Stop to Incentives for Startup Investing

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Proposal’s Effect Would Limit Access to Capital for Small Businesses - An overlooked provision of the new, sweeping tax bill currently under consideration by Congress as part of President Joe Biden’s $3.5 trillion...more

Smith Anderson

Gain Without Pain: Qualified Small Business Stock and Section 1202 of the Internal Revenue Code

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With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more

The Rodman Law Group, LLC

Section 1202 and QSBS, an Often Overlooked Tax Benefit for Small Businesses

In the excitement of starting a new business, and during the headaches associated with growing that business, many entrepreneurs overlook important details that can have huge impacts on their finances. One large blind spot...more

Dickinson Wright

Minimizing Federal Income Tax on Sale of Qualified Small Business Stock

Dickinson Wright on

A taxpayer who is considering the sale of certain stock may have the opportunity to exclude or defer part or all of the gain on such sale. To be eligible for the exclusion or deferral, such stock must be “qualified small...more

Foley & Lardner LLP

Exclusion for Qualified Small Business Stock

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The Protecting Americans from Tax Hikes Act, passed in December 2015, extended an often overlooked provision of the tax code with the potential to provide significant savings to small business owners and non-corporate...more

Polsinelli

Small Business Investors Can Save Big with New IRS Code Amendments

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Recent amendments to the Internal Revenue Code of 1986 (the Code) have significantly expanded the opportunity for tax savings under Section 1202. Section 1202, which was originally added to the Code in 1993, provides relief...more

Wilson Sonsini Goodrich & Rosati

Recent Legislation Permanently Extends Important Tax Planning Opportunity for Investors in Small Businesses

Legislation signed by President Obama on December 18, 2015, makes permanent a U.S. federal income tax exclusion from gross income of 100 percent of the gain recognized by non-corporate taxpayers on the sale or exchange of...more

Orrick, Herrington & Sutcliffe LLP

Congress Extends 100% Exclusion For Gains From Sales Of Qualified Small Business Stock

As a pleasant surprise to many investors, the recently enacted American Taxpayer Relief Act of 2012 (the “Act”) extends the 100% exclusion for gains from sales of Qualified Small Business Stock (“QSB Stock”) to QSB Stock...more

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