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
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
Employees of startups can find the world of stock options and financing rounds to be overwhelming, which may lead to missed opportunities. Even though QSBS is still a new term to experienced investors, employees of small businesses, and startups. They should familiarize themselves with the tax benefits … Read More
As more and more small business owners and investors familiarize themselves with the term QSBS, they may be eager to learn if and how they can qualify for this attractive tax incentive. Ineligible Industries Outlined under Section 1202 Instead of outlining eligible industries, Section 1202 of the IRC outlines … Read More
Qualified small business stock (QSBS) has been around with its associated tax benefits since 1993 with a rise in interest concerning section 1202--which outlines QSBS--after TCJA went into effect. The Tax Cuts and Jobs Act, which was enacted on January 1, 2018, specifies many changes that affect both … Read More
Two recent IPOs earned venture capitalists billions through their stock market debut: data platform, Confluent, and health tech company, Doximity. Confluent raised an impressive $828 million and Doximity a not-so-paltry $606 million. Behind the scenes, four venture capital firms were quietly named the winners of the day. Which … Read More
The Most Significant Change to Colorado's Tax Code in Over a Decade Colorado’s proposed tax reform has officially become a reality. On June 23rd, Governor Jared Polis signed into law the most significant changes to the tax code that the state has seen in over a decade. Since … Read More
A new opportunity zone fund known by the acronym GRASS™ (Growth Resources, Assets, Safety, & Stability) is now open to investors. GRASS™ is a Regulation A+ offering, also known as a “mini-IPO,” which allows small companies to sell shares publicly by exempting them from many of the … Read More
New Capital Gains Tax Met with Lawsuits The State of Washington’s recent introduction of a new capital gains tax was met with two lawsuits within a matter of weeks. The first lawsuit was filed by the Freedom Foundation, a conservative think tank based in the state, which took … 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