(a) Nonrecognition of gain In the case of any sale of qualified small business stock held by a taxpayer other than a corporation for more than 6 months and with respect to which such taxpayer elects the application of this section, gain from such sale shall be recognized only to … Read More
Under Section 1202 there are no requirements for applying for QSBS the day stock is purchased or keeping records over the course of the holding period. Even though you do not have to keep records while holding the QSBS you should. It would be maniacal to try … Read More
Not sure if the stock you’re invested in is QSBS, learn more about our QSBS Monitoring Platform What even is this so called SAFE note? A "SAFE" note stands for simple agreement for future equity. SAFE notes were invented by the famous Silicon Valley accelerator fund Y Combinator. Since … Read More
A "SAFE" note stands for simple agreement for future equity. SAFE notes were invented by the famous Silicon Valley accelerator fund Y Combinator. Since 2013, SAFEs have become popular with founders because they were initially supposed to be fairer to founders, but that is not always the … Read More
Contingent payments can be ambiguous, which causes headaches for transaction tax planning. A few examples of contingent payments are (i) fixed installment payments if a certain level of earnings is met or (ii) contingent payments based on a percentage of the operating cash flow over the next … Read More
The tax code does not directly say if you make a second stock acquisition in a non-QSB stock that it will not affect your first stock's QSBS qualification, but the two purchases will be treated as mutually exclusive. Even if the second stock did qualify for section … Read More
(a)General rule In the case of the mines, wells, and other natural deposits listed in subsection (b), the allowance for depletion under section 611 shall be the percentage, specified in subsection (b), of the gross income from the property excluding from such gross income an amount equal to any rents or … Read More
Fair market value (FMV) is the price in terms of cash equivalents that property would be sold for between a willing and able buyer and seller. The transaction must be considered arm's length, meaning that it was (i) not between related parties for a low ball amount … Read More
(a)In general Except as provided in subsection (e)— (1)Application to individuals In the case of an individual, there is hereby imposed (in addition to any other tax imposed by this subtitle) for each taxable year a tax equal to 3.8 percent of the lesser of— (A) net investment income for such taxable … Read More
(a)Treatment of certain stock purchases (1)Acquisition by related corporation (other than subsidiary) For purposes of sections 302 and 303, if— (A)one or more persons are in control of each of two corporations, and (B)in return for property, one of the corporations acquires stock in the other corporation from the person (or persons) so in control,then (unless paragraph … Read More