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This creates a potential planning opportunity involving operating a start-up as a partnership for several years and then incorporating the partnership and in the process, issuing QSBS to the partners in exchange for their partnership interests. Both a partnership’s assets and partnership interests qualify as a property that can be contributed by a partnership or LLC to a C corporation (generally in a Section 351 exchange) in exchange for QSBS. The planning opportunity afforded through the incorporation of a partnership arises out of the fact that for Section 1202 gain exclusion purposes, the tax basis of property contributed in exchange for QSBS is deemed to be the fair market value of the property at the time of contribution. If a partnership is incorporated, the enterprise value of the partnership’s business would generally be treated as the fair market value of the contributed property. So, if the owners of a business decide to operate a start-up through an LLC or limited partnership and incorporate the business only after the enterprise value has increased substantially, the 10X Basis Cap could substantially increase the owners’ aggregate gain exclusion. Section 1202 also provides that when appreciated property is contributed in exchange for QSBS, the difference between the tax basis of the property and its fair market value for Section 1202 purposes does not qualify for the gain exclusion when the QSBS is eventually sold. Here is an example of how the 10X Basis Cap works when a partnership is converted to a C corporation and QSBS is issued to the partners. If John Smith and Susan Jones operate their business as equal owners in the early years through XYZ LLC, and incorporate the business when the fair market value of XYZ LLC’s business is $25 million, each of them will have a $112.5 million (10 x $12.5 million – $12.5 million) gain exclusion under Section 1202 when they sell their XYZ Corp. QSBS after five years. Contrast this result with an example where John Smith and Susan Jones each initially capitalize XYZ Corp. with $50,000 and sell their QSBS for $250 million after seven years. In this second example, each of John Smith and Susan Jones gain exclusion would be limited to the standard $10 Million Cap.” 2023.06.02 21:13 ZedFullTv QUESTION. “Mutlu olmamız için casino gerekli her şeye sahibiz, ama mutlu değiliz.