Program Details
2025-10-10 14:00:00
Over 1,000+ webinars
Course Overview
2025-10-10 14:00:00
2h CLE Credits
Intermediate
2
2:00 pm - 2:30 pm ESTThis session covers the foundational requirements for Qualified Small Business Stock under Section 1202, including C Corporation status, original issuance rules, and the critical gross asset value test (now $75M post-OB3). Participants will learn about active business requirements, disqualified businesses, redemption rules, and best practices for maintaining audit-ready documentation throughout the holding period.
Christopher Steele BrownMark A. Melton 2:30 pm - 3:00 pm ESTThis session examines how to calculate the QSBS exclusion amount, including the base exclusion limits ($10M pre-OB3, $15M post-OB3) and the powerful 10x basis alternative. Attendees will explore exclusion percentages across different eras, the mechanics of multiple issuances, and how the new three-year and four-year holding periods under OB3 create partial exclusion opportunities with important planning considerations.
Christopher Steele BrownMark A. Melton 3:00 pm - 3:10 pm ESTA brief intermission allowing participants to refresh before continuing with pass-through entity considerations. Use this time to review notes and prepare questions for the remaining sessions.
Christopher Steele BrownMark A. Melton 3:10 pm - 3:40 pm ESTThis session addresses the complexities of holding QSBS through partnerships and S Corporations, including partner-level determinations for the 10x basis calculation and timing requirements for partnership interest ownership. Key topics include carried interest treatment, permitted transfers such as gifts and death transfers, and critical prohibitions on contributing QSBS into partnerships.
Christopher Steele BrownMark A. Melton 3:40 pm - 4:10 pm ESTThis practical session explores common transaction structures including contributing QSBS to holding corporations, rollover structures, and partnership division pitfalls that can destroy QSBS status. Participants will learn strategies for converting LLCs into QSBS structures, including Section 351 considerations, liability issues under Section 357(c), and business purpose requirements under Section 269.
Christopher Steele BrownMark A. MeltonTax partner focusing on transactional tax matters with particular emphasis on closely held companies, partnerships and S-Corporations. For over fifteen years he has been advising clients regarding the use of Section 1202 qualified small business stock.
Mark A. Melton is a partner in Holland & Knight’s Dallas office and co-chair of the firm’s Tax, Executive Compensation and Benefits Practice Group. He advises on Section 1202 qualified small business stock (QSBS) issues and on the federal income taxation of domestic and international transactions of private equity and hedge funds, other investment partnerships, joint ventures, real estate investment trusts (REITs), and operating businesses.
Tax partner focusing on transactional tax matters with particular emphasis on closely held companies, partnerships and S-Corporations. For over fifteen years he has been advising clients regarding the use of Section 1202 qualified small business stock.
Mark A. Melton is a partner in Holland & Knight’s Dallas office and co-chair of the firm’s Tax, Executive Compensation and Benefits Practice Group. He advises on Section 1202 qualified small business stock (QSBS) issues and on the federal income taxation of domestic and international transactions of private equity and hedge funds, other investment partnerships, joint ventures, real estate investment trusts (REITs), and operating businesses.
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
