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GAINS & LOSSES

Navigating the QSBS rules in pass-through structures

The rules for qualified small business stock (QSBS) become more complex when QSBS is held through a pass-through entity or when the corporation operates through one or more partnerships. This article discusses QSBS eligibility rules, planning opportunities, and areas of uncertainty that taxpayers and practitioners must navigate to preserve the QSBS exclusion.

corporations & shareholders

Sec. 338(h)(10) elections in business acquisitions

A Sec. 338(h)(10) election can allow parties to a business acquisition to treat a statutory stock purchase as a deemed asset sale for income tax purposes, potentially benefiting both the buyer and the seller. This article discusses the election’s mechanics, eligibility rules, and tax consequences, as well as practical deal considerations.