Christopher Karachale Speaking at the ABA 2025 Midyear Tax Meeting

QSBS remains one of the most sought after tax benefits in the Code. This panel will discuss more sophisticated planning and considerations concerning QSBS, including the following: When do the tax savings of QSBS justify the use of a C corporation structure, and how should any conversion between entity types be done? What limits apply to “dividing” businesses, putting QSBS-eligible portions in one or more C corporations while keeping the ineligible portions out? What issues apply to §1045, and what other approaches exist for trying to get QSBS sales to be deferred for five years after original issuance? What issues do funds run into when planning for the QSBS exclusion? What does the future hold for the QSBS exclusion?

Christopher Karachale: "​​Advanced Qualified Small Business Stock (“QSBS”) Planning and Considerations"