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2026-02-27 13:00:00
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Course Overview
2026-02-27 13:00:00
2h CLE Credits
Intermediate
2
This session provides a comprehensive foundation in Section 1202’s permanent gain exclusion framework, covering both issuer-level and shareholder-level eligibility requirements. Attendees will explore the One Big Beautiful Bill Act’s recent changes—including the increased $75 million gross asset threshold and phased holding period exclusions—and learn practical strategies for maintaining qualification throughout the investment lifecycle.
John BungeA brief intermission allowing attendees to refresh and connect with colleagues. Use this time to reflect on key eligibility concepts before diving into trust planning strategies.
John BungeThis session examines how transferring qualified small business stock to non-grantor trusts can multiply the $10-15 million exclusion cap across multiple taxpayers. Participants will learn to navigate trust structures including GRATs, IDGTs, SLATs, and incomplete gift trusts while avoiding common pitfalls such as assignment of income issues, partnership contribution traps, and the Section 643(f) anti-abuse rule.
John BungePlante & Moran, PLLC

Holland & Knight LLP
Plante & Moran, PLLC
Rebecca Pugliesi, J.D., LL.M. (Tax), is a Principal in Plante Moran’s National Tax Office who advises on complex federal tax issues arising in the purchase, sale, and restructuring of family-owned and private equity-owned businesses, with a particular focus on Qualified Small Business Stock (IRC §1202) planning and transaction structuring.

Holland & Knight LLP
John Bunge is a tax and private wealth services attorney who helps clients navigate the confluence of tax planning, business succession planning and estate planning, seeking to find the most elegant solutions possible to reach their goals.
Plante & Moran, PLLC
Rebecca Pugliesi, J.D., LL.M. (Tax), is a Principal in Plante Moran’s National Tax Office who advises on complex federal tax issues arising in the purchase, sale, and restructuring of family-owned and private equity-owned businesses, with a particular focus on Qualified Small Business Stock (IRC §1202) planning and transaction structuring.

Holland & Knight LLP
John Bunge is a tax and private wealth services attorney who helps clients navigate the confluence of tax planning, business succession planning and estate planning, seeking to find the most elegant solutions possible to reach their goals.
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.
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