Originally designed to encourage investors to help the disadvantaged, the Tax Cuts and Jobs Act was signed into law in 2017. With this law came the creation of Opportunity Zones (OZ), socioeconomic locations identified by the government and designated for new business development with the intention of … Read More
United States Tax Court, No. 2917-63, July 23, 1965 Key QSBS Takeaways: In Bardahl Mfg. Corp. v. Commissioner, the United States Tax Court contended that Bardahl Corporation avoided "the imposition of individual income tax on its shareholders, by permitting its earnings and profits to accumulate instead of being … Read More
The implementation of advanced planning strategies is to: (1) reduce or eliminate capital gains tax; (2) reduce future estate tax; and (3) increase asset protection from creditors and lawsuits should be on every founder, owner, and investor’s mind. All strategies revolve around time and the amount of equity … Read More
The implementation of advanced planning strategies to: (1) reduce or eliminate capital gains tax; (2) reduce future estate tax; and (3) increase asset protection from creditors and lawsuits should be on every founder, owner, and investor’s mind. All strategies revolve around time and the amount of equity … Read More
The implementation of advanced planning strategies to: (1) reduce or eliminate capital gains tax; (2) reduce future estate tax; and (3) increase asset protection from creditors and lawsuits should be on every founder, owner, and investor’s mind. All strategies revolve around time and the amount of equity … Read More
The implementation of advanced planning strategies to: (1) reduce or eliminate capital gains tax; (2) reduce future estate tax; and (3) increase asset protection from creditors and lawsuits should be on every founder, owner, and investor’s mind. All strategies revolve around time and the amount of equity … Read More
The implementation of advanced planning strategies to: (1) reduce or eliminate capital gains tax; (2) reduce future estate tax; and (3) increase asset protection from creditors and lawsuits should be on every founder, owner, and investor’s mind. All strategies revolve around time and the amount of equity … Read More
What Types of Businesses Qualify as Qualified Small Businesses (QSBs)? Qualified Small Business Stock (QSBS) is and the associated benefits are subject to more than a few restrictions and conditions. One of those being the actual trade of the business issuing the stock. Rather than clearly outlining the … Read More
On September 02, 2016, the IRS released Private Letter Ruling (PLR 201636003), addressing whether, after several name changes to the company and a conversion from a LLC to a C-corporation, does the reorganization under § 1202(h) and § 368 have any effect on the stock—having no formal … Read More
Tax Court of New Jersey, No. 020999-2010, October 9, 2012 KEY QSBS TAKEAWAY(S): In Aciu v. Director, the taxpayer failed to prove that the language in N.J.S.A. 54A:5–1(c) followed the federal tax exemption on the sale of capital gains under I.R.C. § 1202. Also, the taxpayer failed to … Read More