Trusts & Estates Partner, Stuart Kohn will be a panelist during the Sales, Exchanges & Basis Committee meeting. Stuart will moderate a discussion on tax exemptions for small business stock.
Individuals, including individual partners of venture capital funds, may be entitled under section 1202 to exclude from tax up to $10 million of their gain on sale of stock acquired at original issue from a domestic C corporation, if that C corporation’s aggregate gross assets immediately after the stock issuance did not exceed $50 million, and if that corporation has carried on a qualifying active business. Additional gain may be eligible for deferral under section 1045 by rollover into other small business stock. Panelists will discuss how section 1202 fits into the C vs. pass-through choice-of-entity decision, and point out planning techniques for qualifying for and utilizing the section 1202 exclusion and section 1045 roll-over benefits.