A recent Tax Notes piece by Manoj Viswanathan of the University of California College of the Law, San Francisco argues that the current system for claiming the Qualified Small Business Stock exclusion places too much responsibility on the wrong party. Rather than requiring shareholders to prove Section … Read More
Qualified Small Business Stock is often described as one of the most powerful tax incentives available to founders and early-stage investors. But as a recent FBT Gibbons article by Scott W. Dolson makes clear, Section 1202 planning can become far more complicated when a corporation has any … Read More
Companies that are engaged in activities that do not fall under the definition of a Qualified Trade or Business risk eligibility for their stock qualifying as Qualified Small Business Stock (“QSBS”). All is not lost however if a company partakes in some “non-qualified” activities. Provided the value … Read More
Under IRC Section 1202(e), at least 80% of a company’s assets must be actively utilized in a “qualified trade or business”. To ensure that assets are being actively deployed towards the qualified trade, a limitation exists on the amount of working capital that can be held (IRC … Read More
Navigating the intricate world of tax optimization demands a strategic approach to financial management. Scott Galloway, Professor of Marketing at NYU Stern School of Business and co-host of the enlightening podcast "Prof G Markets" with Ed Elson brings a unique blend of academic insight and practical wisdom … Read More
IRS audit activity regarding QSBS seems to be on the rise. During Q1 2024 we have seen multiple taxpayers receive requests for information, had QSBS claims rejected by the IRS and / or cases have gone to trial. Has the IRS challenged or rejected your QSBS claim? Let … Read More
IRS audit activity regarding QSBS seems to be on the rise. During Q1 2024 we have seen multiple taxpayers receive requests for information, had QSBS claims rejected by the IRS and / or cases have gone to trial. Has the IRS challenged or rejected your QSBS claim? Let … Read More
According to the Internal Revenue Code Section 1202 (I.R.C. §1202), investors can benefit from a substantial tax advantage through Qualified Small Business Stock (QSBS). Under this section, a complete exemption from federal capital gains taxes on profits gained from the sale of QSBS stock held for a … Read More
If you're a business owner, you may be wondering if converting your business from an LLC to a C-corporation is the right move for you. There are a number of factors to consider when making this decision, including your business's size, its stage of development, and its … Read More
The Internal Revenue Code (IRC) Section 1244 is a provision that often remains underutilized by small businesses, primarily due to lack of awareness. This provision can provide significant tax benefits, particularly in instances where business investments do not yield the expected returns. In this article, we aim … Read More