Qualified Small Business Stock Under Irc §1202: Tax-Free Money for the Masses?

California Business Law Practitioner, 31;3 Summer 2016

10 Pages Posted: 17 Jan 2017

Date Written: August 1, 2016

Abstract

After a short analysis of policy considerations regarding qualified small business stock (QSBS), this article explains the general requirements to obtain the gain exclusion provided under IRC §1202. The article also considers the related tax deferral provisions for QSBS contained in IRC §1045. Finally, the article provides a comprehensive review of the (concededly small) universe of case law and administrative guidance from the Internal Revenue Service on QSBS.

Keywords: qualified small business stock, IRC section 1202

JEL Classification: k34

Suggested Citation

Karachale, Christopher A., Qualified Small Business Stock Under Irc §1202: Tax-Free Money for the Masses? (August 1, 2016). California Business Law Practitioner, 31;3 Summer 2016, Available at SSRN: https://ssrn.com/abstract=2894536

Christopher A. Karachale (Contact Author)

Hanson Bridgett LLP ( email )

425 Market Street, 26th Floor
San Francisco, CA 94105
United States
(415) 995-5863 Direct (Phone)
(415) 995-3407 Fax (Fax)

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