About This Course
The Code Sec. 1202 exclusion for the gain on the sale of stock has gained increased attention from the Lower C corporation income tax rates. This CLE course will explain how this exclusion works, how it impacts a C corporation’s business structure, how it can be applied when a business changes from another entity to a C corporation and how it might compare to exit strategies of other businesses. The course will also explain how to shift to a partnership status from a corporate one after the tax benefits from being a C corporation have expired. Specific examples, such as Dynamo Holdings Ltd. V. Commissioner, T.C Memo 2018-61, which addresses sales and loans between businesses held by related parties will be discussed as well as how it creates a limit on the application of a taxpayer-friendly case on business transfers but simultaneously may bolster the cases of those with a relaxed loan documentation.