Did you know that gain remaining after a partial exclusion on a sale of Qualified Small Business Stock (QSBS) is subject to a 28% capital gains rate?

By Marko J. Belej

July 30, 2025

Content by Marko Belej with assistance by summer associate Natalie Esshaki

Before the One Big Beautiful Bill was passed, Section 1202 allowed a taxpayer who held QSBS for a minimum of 5 years to exclude 100% of the gain from gross income. Now, Section 1202 has a more relaxed tiered-system in place, that ties the…

Taft Tax Insights

Did you know you can receive profits interest tax-free even when the services are not rendered directly to the partnership?

By James Duffy

February 14, 2024

Walking to the next location — Taylor Grote, Unsplash

In the recent case of ES NPA Holding LLC v. Commissioner, the IRS argued that a profits interest can only be received tax-free by a service provider when the service is rendered directly to or for the benefit of the entity issuing the interest. The facts of the case are complicated, but in short, in the…