Article
QSBS Stacking: Leveraging Gifts And Trusts For Additional Section 1202 Exclusions
Section 1202 of the Internal Revenue Code offers substantial tax benefits for qualified small business stock (QSBS) holders, allowing exclusion of gains up to $10 million or more per taxpayer. Strategic gifting of QSBS shares to family members, trusts, and other entities can multiply these exclusions, potentially sheltering tens of millions in capital gains from federal taxation while navigating complex timing, gift tax, and trust structure considerations.
Foley & Lardner