On April 28, 2017, the IRS released Private Letter Ruling (PLR 201717010), addressing whether a Founder of a C-corporation operating in the services for health providers is qualified for the partial exclusion of gain under the Section 1202(a). Additionally, whether the corporation meets QSBS criteria for being … 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
United States Tax Court, Nos. 930–07, 1384–07, 13303–07, 29011–08, 29090–08, January 19, 2012 KEY QSBS TAKEAWAY(S): In Owen v. Commissioner, the taxpayer met the 60–day requirement of section 1045(a)(1) because the stock purchase agreement transaction was signed on June 17, 2002, and the sold Family First Companies shares--amounting to … Read More
United States Tax Court, No. 17291–07, February 1, 2010 KEY QSBS TAKEAWAY(S): In Natkunanathan v. Commissioner, the taxpayer misused the definition under §1202(f) and argued stock options are equivalent to the sale or exchange of stock. Another key takeaway is the taxpayers failure to provide evidence that the … Read More
United States Tax Court, No. 3769-10, August 30, 2012 KEY QSBS TAKEAWAY(S): In Holmes v Commissioner, the taxpayer provided no evidence to demonstrate that they received the shares at original issuance (required as per IRC §1202(c)(1)(B)), and therefore failed to substantiate that their stock holdings qualified as QSBS. … Read More
On September 25, 2014, the IRS released Private Letter Ruling (PLR 201436001), addressing whether a corporation operating in the pharmaceutical field meets the Section 1202 / QSBS criteria of being a “Qualified Trade or Business”. The company in question in this PLR: works with pharmaceutical clients to commercialize experimental … Read More
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