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Qualified Small Business Stock Tax Liability

Hanson Bridgett

Timing is Everything for QSBS After the One Big Beautiful Bill Act

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The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, establishes new phased-in benefits for Qualified Small Business Stock (QSBS) held for at least three years. ...more

Cole Schotz

Salt Provisions In The One Big Beautiful Bill Act: A Mirage Rather Than A Panacea Of Relief For High-Income Earners

Cole Schotz on

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law ushering in sweeping federal tax changes. The legislation notably expands the Qualified Business Income (QBI) deduction for professionals...more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

Frost Brown Todd on

Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Patterson Belknap Webb & Tyler LLP

Section 83(b) Elections — Should You Pay Taxes Now?

In startups and early-stage companies, founders often receive restricted equity grants as compensation for their services. With some planning, founders can potentially lower the taxes they pay on the appreciation of the...more

DarrowEverett LLP

Unlocking Tax-Free Gains: The Power of QSBS in Mergers & Acquisitions

DarrowEverett LLP on

Internal Revenue Code (IRC) Section 1202 offers a significant tax incentive for investors in qualified small business stock (QSBS). This provision allows eligible shareholders to exclude up to 100% of capital gains realized...more

Farrell Fritz, P.C.

Qualified Small Business Stock – Overview and Useful Strategies

Farrell Fritz, P.C. on

Founders, entrepreneurs, venture capitalists and other investors (all of which are collectively referred to herein as “investors”) should be familiar with Internal Revenue Code Section 1202, a valuable provision that...more

Keating Muething & Klekamp PLL

Sale of QSBS and Installment Sale Reporting

In recent years, the utilization of qualified small business stock (“QSBS”) has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section...more

Mintz - Tax Viewpoints

Considering Converting an LLC into a Corporation? Here Are the QSBS Issues You Should Be Thinking About

A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax-related factors that need to be considered, this is often (at least in...more

Wilson Sonsini Goodrich & Rosati

IRS Rules That an Enterprise Cloud Application Software Company Is Engaged in a Qualified Trade or Business for QSBS Purposes

On May 12, 2023, the Internal Revenue Service (IRS) published private letter ruling 202319013 (the PLR), which concluded that an enterprise cloud application software company is engaged in a qualified trade or business for...more

Miller Nash LLP

Today in Tax: Model Global Minimum Tax Rules and Gain Exclusion for Software Companies

Miller Nash LLP on

Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Cozen O'Connor

House Ways and Means Committee Proposes Reduction of QSBS Exclusion

Cozen O'Connor on

On September 15, 2021, the House Ways and Means Committee approved its draft tax legislation that was released on September 13, 2021, as part of the “Build Back Better” budget reconciliation program. Included in the draft...more

Rivkin Radler LLP

The President’s Recent Tax Proposals: What Do They Mean For Business Owners?

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A Night to Remember? Did you listen to the President’s speech last Wednesday? He addressed a joint session of Congress to pitch the Administration’s $1.8 trillion American Families Plan. Due to COVID-related...more

Orrick, Herrington & Sutcliffe LLP

100% QSBS Exclusion Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

Orrick, Herrington & Sutcliffe LLP

100% Exclusion for Gains from Qualified Small Business Stock Soon to be Made Permanent

The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more

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