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QSBS and Section 1202: what it is and when it can apply

Qualified small business stock, or QSBS, is one of the most valuable provisions in the tax code for early shareholders, and one of the most misunderstood. It can exclude a large portion, sometimes all, of the gain on qualifying stock from federal tax. It also has strict requirements, and many shares don't qualify.

The basic tests

  • The company must be a domestic C corporation.
  • You must have acquired the stock directly from the company at original issuance, not bought it from another shareholder.
  • The company's gross assets must have been below a limit when your stock was issued: $50 million for stock issued on or before July 4, 2025, and $75 million for stock issued after.
  • The company must use its assets in an active, qualifying business. Some fields, including many professional services and financial businesses, are excluded.
  • You must hold the stock for a minimum period.

How much can be excluded

The exclusion is capped per company at the greater of a dollar limit or 10 times your basis in the stock. For stock issued after July 4, 2025, the dollar limit is $15 million, indexed for inflation in future years, up from $10 million. The holding period rules changed as well.

Time held Stock issued on or before July 4, 2025 Stock issued after July 4, 2025
Less than 3 years No exclusion No exclusion
3 years No exclusion 50%
4 years No exclusion 75%
5 years or more 100% (for stock acquired after September 27, 2010) 100%

Details that trip people up

  • For shares from exercised options, the holding period generally starts when you exercise, not when the options were granted.
  • For RSUs, the relevant date is generally when the shares are delivered to you.
  • The asset test applies when your specific shares were issued. Shares issued after a company has grown past the limit generally don't qualify, even if earlier shares did.
  • States don't all follow the federal rule. California, for example, doesn't offer the exclusion.
Ask, don't assume. Whether your shares qualify depends on facts only your company and a tax professional can confirm: when your shares were issued, the company's asset size at that time, and how you acquired them. Treat QSBS as a question to ask, not an assumption to plan around.