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Rubric Financial

Tax

QSBS (Qualified Small Business Stock, §1202)

A tax provision excluding up to $10M of capital gain on qualifying small business stock held 5+ years.

Section 1202 excludes 100% of capital gain (up to $10M or 10× basis, whichever is greater) on the sale of qualified small business stock held more than 5 years.

To qualify, the issuer must be a domestic C-corp, gross assets at and after issuance must be under $50M, and the corporation must conduct an active business in qualified industries (excluding professional services, financial services, hospitality).

Common pitfalls

  • Converting an LLC to C-corp doesn't reset the QSBS clock — only stock issued post-conversion qualifies
  • The 5-year holding period is strict — even one day short disqualifies
  • Many states (including California) don't conform to §1202 — state tax still applies

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