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Transferring Qualified Small Business Stock to Trusts: Income, Gift, and Estate Tax Risks and Planning Strategies

Master Section 1202 QSBS eligibility requirements, post-OBBBA planning strategies, and trust transfer techniques to multiply gain exclusions.

2026-02-27 13:00:00

Program Details

2026-02-27 13:00:00

2026-02-27 13:00:00

Over 1,000+ webinars

Program Details

2026-02-27 13:00:00

Program Details

2026-02-27 13:00:00

Over 1,000+ webinars

2026-02-27 13:00:00

Course Overview

Maximizing QSBS Exclusions Through Strategic Planning

2026-02-27 13:00:00

Participants will learn Section 1202 eligibility requirements and trust-based strategies to multiply gain exclusions. These techniques enable founders and investors to permanently shelter millions in capital gains.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
Exclusion Framework
Section 1202 provides permanent gain exclusion up to $15 million post-OBBBA.
02
Eligibility Requirements
Both issuer-level and shareholder-level requirements must be satisfied for qualification.
03
OBBBA Changes
New phased holding periods and increased $75 million gross asset threshold apply.
04
Trust Strategies
Non-grantor trusts receive separate exclusion caps, enabling multiplication of benefits.
05
Pass-Through Entities
Partnerships and S corporations can hold QSBS with special allocation rules.
06
Common Pitfalls
Redemptions, partnership contributions, and timing issues can destroy QSBS qualification.

Program schedule

clock 1:00 pm - 2:00 pm EST

QSBS Section 1202 Eligibility and Post-OBBBA Planning

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.

Rebecca PugliesiRebecca Pugliesi
John BungeJohn Bunge
clock 2:00 pm - 2:10 pm EST

Networking Break

A 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.

Rebecca PugliesiRebecca Pugliesi
John BungeJohn Bunge
clock 2:10 pm - 3:10 pm EST

Strategic QSBS Transfers to Trusts and Exclusion Multiplication

This 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.

Rebecca PugliesiRebecca Pugliesi
John BungeJohn Bunge
Rebecca Pugliesi

Rebecca Pugliesi

Plante & Moran, PLLC

John Bunge

John Bunge

Holland & Knight LLP

Rebecca Pugliesi

Rebecca Pugliesi

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.

Education & Credentials

J.D., LL.M. (Tax), Michigan-licensed attorney

Recognition & Leadership

Frequent speaker on M&A tax structuring and QSBS strategy

Professional Involvement

Officer of the State Bar of Michigan Tax Section Council

Experience

Her work regularly involves modeling what-if exit outcomes and designing structures intended to preserve and maximize tax attributes, especially where QSBS benefits intersect with ownership planning, entity choice, and timing. She brings a deal-and-planning perspective grounded in how Section 1202 eligibility is maintained and lost over the life of an investment, including shareholder eligibility, documentation practices, and risk areas where IRS guidance is limited.
John Bunge

John Bunge

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.

Experience

Mr. Bunge's wealth preservation experience includes income, gift, estate and generation-skipping transfer tax minimization through the use of irrevocable trusts, sales and gifts to trusts, charitable-interest trusts and grantor-retained annuity trusts. He advises families on formation of investment entities such as family limited partnerships and family LLCs, helps clients reach charitable goals using charitable giving techniques, advises on formation and operation of tax-exempt organizations including private foundations, counsels families on formation, structuring and operation of family offices and private trust companies, helps clients minimize income taxes through individual, partnership and corporate tax planning, and has experience assisting taxpayers through IRS audits, appeals and U.S. Tax Court litigation.
Rebecca Pugliesi

Rebecca Pugliesi

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.

Education & Credentials

J.D., LL.M. (Tax), Michigan-licensed attorney

Recognition & Leadership

Frequent speaker on M&A tax structuring and QSBS strategy

Professional Involvement

Officer of the State Bar of Michigan Tax Section Council

Experience

Her work regularly involves modeling what-if exit outcomes and designing structures intended to preserve and maximize tax attributes, especially where QSBS benefits intersect with ownership planning, entity choice, and timing. She brings a deal-and-planning perspective grounded in how Section 1202 eligibility is maintained and lost over the life of an investment, including shareholder eligibility, documentation practices, and risk areas where IRS guidance is limited.
John Bunge

John Bunge

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.

Experience

Mr. Bunge's wealth preservation experience includes income, gift, estate and generation-skipping transfer tax minimization through the use of irrevocable trusts, sales and gifts to trusts, charitable-interest trusts and grantor-retained annuity trusts. He advises families on formation of investment entities such as family limited partnerships and family LLCs, helps clients reach charitable goals using charitable giving techniques, advises on formation and operation of tax-exempt organizations including private foundations, counsels families on formation, structuring and operation of family offices and private trust companies, helps clients minimize income taxes through individual, partnership and corporate tax planning, and has experience assisting taxpayers through IRS audits, appeals and U.S. Tax Court litigation.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.4
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.4
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

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Live stream programs

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Trusted by Legal Professionals

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10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Approved
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Approved
Hawaii
Approved
Idaho
Pending
Illinois
Approved
Indiana
Approved
Iowa
Pending
Kansas
Approved
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Approved
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Approved
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Approved
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Approved
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Approved
Wyoming
Pending

Alabama

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

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs