Program Details
2026-10-09 12:00:00
Over 1,000+ webinars
Course Overview
2026-10-09 12:00:00
2h CLE Credits
Intermediate
2
12:00 pm - 1:00 pm ESTThis session walks attorneys through the full Section 1202 eligibility framework, as amended by OBBBA, covering the three structural changes to the exclusion cap, holding period tiers, and aggregate gross assets threshold, alongside the five core requirements that remain unchanged. Attorneys learn how to evaluate whether a client’s company qualifies, how to structure or convert entities to access QSBS treatment, and how to avoid the pitfalls identified in recent Tax Court and Court of Federal Claims decisions. They leave equipped to audit existing holdings, counsel on conversion mechanics, and spot the 31.8% rate trap that can make partial exclusions more costly than expected.
Matthew E. RappaportMatthew E. Foreman 1:10 pm - 2:10 pm ESTThis session teaches attorneys how to multiply the Section 1202 exclusion across multiple taxpayers through gifting and non-grantor trust structures, and how to navigate state non-conformity before a client’s exit. It covers the mechanics of exclusion stacking under both pre- and post-OBBBA caps, the assignment-of-income timing rules that can undo a transfer at the worst moment, and the state-level strategies, including trust situs selection and relocation, that determine whether the exclusion survives at the state level. Attorneys leave with a working framework for structuring gifts and trusts before any sale process begins and for identifying which clients face material state tax exposure despite a clean federal exclusion.
Matthew E. RappaportMatthew E. ForemanMatthew E. Rappaport is Vice Managing Partner of Falcon Rappaport & Berkman LLP and chairs the firm’s Taxation and Private Client Groups. His practice concentrates on taxation as it relates to real estate, closely held businesses, private equity funds, family offices, and trusts and estates, advising on tax planning, structuring, and compliance for commercial real estate projects, all stages of the business life cycle, generational wealth transfer, family business succession, and executive compensation.
Matthew E. Foreman is a Partner at Falcon Rappaport & Berkman LLP, where he co-chairs the firm’s Taxation Practice Group. He advises on Qualified Small Business Stock (QSBS), entity selection, and the tax-efficient return of capital to owners, and structures taxable and tax-free combinations, mergers, sales, acquisitions, and divisive reorganizations, including cross-border transactions.
Matthew E. Rappaport is Vice Managing Partner of Falcon Rappaport & Berkman LLP and chairs the firm’s Taxation and Private Client Groups. His practice concentrates on taxation as it relates to real estate, closely held businesses, private equity funds, family offices, and trusts and estates, advising on tax planning, structuring, and compliance for commercial real estate projects, all stages of the business life cycle, generational wealth transfer, family business succession, and executive compensation.
Matthew E. Foreman is a Partner at Falcon Rappaport & Berkman LLP, where he co-chairs the firm’s Taxation Practice Group. He advises on Qualified Small Business Stock (QSBS), entity selection, and the tax-efficient return of capital to owners, and structures taxable and tax-free combinations, mergers, sales, acquisitions, and divisive reorganizations, including cross-border transactions.
Requirements
The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.
Formats
