Monthly Archives: August 2020

QSBS for Investment Funds

As a manager of an Investment Fund, it is imperative to know both what the tax implications may be for investments you’re considering entering and tax treatment of gains for your Limited Partners as they are sure to ask you.  QSBSExpert is here to help! Which Portfolio Companies … Read More

Section 368

(a) Reorganization (1) In general For purposes of parts I and II and this part, the term “reorganization” means— (A) a statutory merger or consolidation; (B) the acquisition by one corporation, in exchange solely for all or a part of its voting stock (or in exchange solely for all or a … Read More

Section 351

(a) General rule No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c)) of the corporation. (b) … Read More

What is a tiered partnership?

A tiered partnership involves an upper-tier, the parent or holding company, and a lower-tier, the subsidiary. Generally, the partners of the parent company will have pass-through income or losses from the subsidiary that passes through the parent. For tax purposes, the partners of the parent company are … Read More