In a previous article, The Often-Overlooked Benefits of Qualified Small Business Stock, I discussed the significant benefits available to taxpayers holding qualified small business stock (“QSBS”), which is defined under Section 1202 of the Internal Revenue Code (“IRC”). While significant then, the recently enacted One Big Beautiful Bill (“OBBB”)[1] amended IRC § 1202[2] to substantially…
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If you started a business organized as a C corporation, you may be able to avoid some, and possibly all, tax liability when you sell the stock of the C corporation. As previously written upon by Gray Edmondson,[1] Section 1202 of the Internal Revenue Code (“Code”) provides for the exclusion of gain on Qualified Small…
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In a recent Chief Counsel Advice (“CCA”) issued by the IRS, the IRS concluded that the taxpayer’s sale of stock did not qualify for the gain exclusion as Qualified Small Business Stock (“QSBS”) under Section 1202 since the business of the corporation was akin to brokerage services.[1] The IRS concluded that the corporation’s business, one…
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