One of the many areas of 26 U.S.C.A. § 1202 that is creating the most questions from corporations looking to determine if their company qualifies for the tax exemption falls under Section 1202(e)(3)(A); which broadly states how the IRS defines excluded trades or businesses for the qualification … Read More
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
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
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
Not sure if the stock you’re invested in is QSBS, learn more about our QSBS Monitoring Platform As investors hear more and more about the qualified small business stock tax exemptions, they may be looking at their own portfolio and assets to see where this capital gains exclusion … Read More
For most of us it is a dream to be living retirement on a beach while sipping a pina colada. If you are reading this, I hope you are not wasting your time on the beach reading about taxation, unless you think you own qualified small business … Read More
Cannabis Investors Need to Look Into QSBS Those looking to break into the growing cannabis industry through entrepreneurship would be wise to familiarize themselves with section 1202 of the IRC, the capital gains exclusion which allows for holders of QSBS to take the $10,000,000 tax-free. The cannabis industry attracts … Read More
On September 25, 2014, the IRS released Private Letter Ruling (PLR 201436001), addressing whether a corporation operating in the pharmaceutical field meets the Section 1202 / QSBS criteria of being a “Qualified Trade or Business”. The company in question in this PLR: works with pharmaceutical clients to commercialize experimental … Read More
On April 9, 2021, the IRS released Private Letter Ruling (PLR 202114002), addressing whether a corporation operating in the insurance field meets the Section 1202 / QSBS criteria of being a “Qualified Trade or Business”. The company in question in this PLR: helps customers obtain property, casualty, surety, personal, … Read More
It is possible to challenge / dispute the IRS’s determination regarding the eligibility of your business. For example, in a ruling letter issued on May 22, 2014, Ruling 201436001, the IRS examined whether a corporation which provides products and services primarily in connection with the pharmaceutical industry, helping to … Read More