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
To qualify as being able to issue QSBS stock, the corporation needs to be developing or producing a product for businesses or consumers. If the principal asset of the corporation is the skill or reputation of one or more employees than the corporation does not qualify for … Read More
In order to qualify as a “Qualified Small Business”, Section 1202 requires that the corporation to be in a “qualified trade or business.” The general intent of the QSBS tax exclusion is to incentivize investment in entrepreneurship of innovative companies to help drive future economic growth. Example of … Read More