Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-structuring-memo-qsbs.docx
tax-structuring-memo-qsbs.docx
Parties
Harkness LLP
Cobalt Ventures LP
Ames LLP
General Corp
Equity Inc
Dates
February 7, 2026
February 9, 2026
June 15, 2023
December 31, 2025
January 18, 2026
September 12, 2023
September 27, 2010
February 10, 2031
September 13, 2028
Amounts
$12,000,000
$10,000,000
$7,200,000
$72,000,000
$1,400,000
$185,000
$50,000,000
$30,000,000
$42,000,000
$2.6786
Obligations
Definition of QSBS — Five Requirements For stock to qualify as QSBS, five cumulative requirements must be satisfied under IRC § 1202(c) and (d)
All five requirements must be met; failure to satisfy any single requirement disqualifies the stock from QSBS treatment
The stock must be issued by a "qualified small business," which is defined in § 1202(d)(1) as a domestic C-corporation
The issuing corporation must be a C-corporation at the time of issuance and must remain a C-corporation during substantially all of the taxpayer's holding period
At the time of issuance, the corporation's aggregate gross assets must not exceed $50,000,000
During substantially all of the taxpayer's holding period, the corporation must use at least 80% of its assets (by value) in the active conduct of one or more "qualified trades or businesses