New 50% exclusion for gain from QSB stock.

The Tax AdviserVol. 25 Nbr. 5, May 1994

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Summary


Qualified small business

The 50% exclusion of gain from the sale of qualified small business stock under Internal Revenue Code section 1202 makes C corporation status more appealing if corporate income is being retained, but S corporations still provide greater tax benefits if stock sale is contemplated. The opportunities to convert from S status to C status to benefit from the 50% exclusion are limited. Qualified small business stock cannot have been issued for other stock unless that other stock was also qualified. The best option for the S corporation wishing to qualify may be to recapitalize so that future appreciation will receive the 50% exclusion.

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Extract


New 50% exclusion for gain from QSB stock.

The new tax benefit provided by Sec. 1202 appears to be helpful to an existing C corporation that meets the requirements of a qualified small business (QSB) (as defined in Sec. 1202(d)) and desires to raise additional equity capital. It al...

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