As always, the law is defined not necessarily by how it’s written, but by how it’s carried out.
There has been little in the way of guidance issued by courts and the IRS on QSBS, with one court case along with three IRS Private Letter Rulings (PLRs). Links are provided to each, along with some commentary.
It’s important to emphasize that PLRs apply only to the specific case in question, and cannot be relied upon as precedent. Nevertheless, they provide an important window into how the IRS has defined a “qualified trade or business” when prompted.
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