On June 25, 2021, the IRS released Private Letter Ruling (PLR 202125004), addressing whether a company that would "evaluate, measure, design, fabricate, manufacture, adjust, fit, and service" prescriptions for a third-party healthcare provider is not considered to be engaged in a business involving the performance of services … Read More
Going public via a Special Purpose Acquisition Company (SPAC) acquisition is quickly becoming one of, if not the main way to IPO. The number of SPAC IPOs rose at a value of 320% from 2019 to 2020. Also, as of April 30, 2021, there were nearly double … Read More
On September 02, 2016, the IRS released Private Letter Ruling (PLR 201636003), addressing whether, after several name changes to the company and a conversion from a LLC to a C-corporation, does the reorganization under § 1202(h) and § 368 have any effect on the stock—having no formal … Read More
On April 28, 2017, the IRS released Private Letter Ruling (PLR 201717010), addressing whether a Founder of a C-corporation operating in the services for health providers is qualified for the partial exclusion of gain under the Section 1202(a). Additionally, whether the corporation meets QSBS criteria for being … Read More
Employees of startups can find the world of stock options and financing rounds to be overwhelming, which may lead to missed opportunities. Even though QSBS is still a new term to experienced investors, employees of small businesses, and startups. They should familiarize themselves with the tax benefits … Read More
As more and more small business owners and investors familiarize themselves with the term QSBS, they may be eager to learn if and how they can qualify for this attractive tax incentive. Ineligible Industries Outlined under Section 1202 Instead of outlining eligible industries, Section 1202 of the IRC outlines … Read More
Complexity Surrounding the $50M Gross Asset Test At first glance, it might seem like the $50M Gross Asset Test is simple, but the reality is that in certain circumstances, it can be much more complex. For example, if a financing round has multiple closings, part of the stock … Read More
Tax Court of New Jersey, No. 020999-2010, October 9, 2012 KEY QSBS TAKEAWAY(S): In Aciu v. Director, the taxpayer failed to prove that the language in N.J.S.A. 54A:5–1(c) followed the federal tax exemption on the sale of capital gains under I.R.C. § 1202. Also, the taxpayer failed to … Read More
Maximizing gains from Qualified Small Business Stock (QSBS) involves an understanding of the applicable tax laws. One key factor is the time period the IRS is allotted to retroactively audit reported QSBS, also known as the statute of limitations. What is a Statute of Limitations? Broadly speaking, a statute … Read More
Not sure if the stock you’re invested in is QSBS, learn more about our QSBS Monitoring Platform 83(b) Election Basics An 83(b) election allows an individual to accelerate the date on which restricted shares are subject to ordinary income taxes, and potentially pay a lower tax now versus a … Read More