QSBS Case Law

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.

 

IRS Rulings:

QSBS IRS Ruling: PLR 202114002 – Potential QSBS implications for Insurance, Brokerage Services and FinTech Corporations?
QSBS IRS Ruling: PLR 201436001 – Potential QSBS implications for healthcare related 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”
QSBS IRS Ruling: PLR 202125004- Potential QSBS Implications for a Medical Manufacturer Company Being a Qualifying Business under §1202(e)(3)

Tax Court Rulings:

QSBS Court Ruling: Holmes v. IRS Commissioner-Original Issuance Questions (IRC §1202(c)(1)(B))
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 Court Ruling: Aciu v. Director-Do All States Conform with I.R.C §1202 under Federal Tax Law?
QSBS Court Ruling: Bardahl Mfg. Corp. v. Commissioner-Reasonable Working Capital (§1202(e)(6))

QSBS has implications for different stakeholders.
Explore the nuances.

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Individual Investor

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Investment Fund

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Founder

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Employee

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Service Provider

Additional resources

Frequently asked questions regarding Section 1045 rollovers Read More
Find QSBS eligible companies looking for new investors Read More

This article does not constitute legal or tax advice. Please consult with your legal or tax advisor with respect to your particular circumstance.