The QSBS code is subject to interpretation, so it is useful to look at how the code has been applied through relevant case law, to see if there are nuances that may apply to your particular situation.
QSBS IRS Ruling: PLR 202114002 – Potential QSBS implications for Insurance, Brokerage Services and FinTech Corporations?
QSBS IRS Ruling: PLR 201717010- Companies Questioning if They are a “Qualified Business” in the Health Services under § 1202(e)(3)
QSBS IRS Ruling: PLR 201636003- Potential QSBS Implications Surrounding What Determines a Stock a “Qualified Small Business Stock”
Tax Court Rulings:
QSBS Court Ruling: Natkunanathan v. Commissioner of Internal Revenue- Can acquired stock options during a merger and acquisition qualify for QSBS?
QSBS Court Ruling: Owen v. Commissioner of Internal Revenue-Why is an “active business” requirement under (§1202(e)) important when applying a §1045?
QSBS has implications for different stakeholders.
Explore the nuances.
This article does not constitute legal or tax advice. Please consult with your legal or tax advisor with respect to your particular circumstance.