Skip to main content

Main menu

  • Home
  • Current Issue
  • Past Issues
  • Videos
  • Submit an article
  • More
    • About JPE
    • Editorial Board
    • Published Ahead of Print (PAP)
  • IPR Logo
  • About Us
  • Journals
  • Publish
  • Advertise
  • Videos
  • Webinars
  • More
    • Awards
    • Article Licensing
    • Academic Use

User menu

  • Sample our Content
  • Request a Demo
  • Log in

Search

  • Advanced search
The Journal of Private Equity
  • IPR Logo
  • About Us
  • Journals
  • Publish
  • Advertise
  • Videos
  • Webinars
  • More
    • Awards
    • Article Licensing
    • Academic Use
  • Sample our Content
  • Request a Demo
  • Log in
The Journal of Private Equity

The Journal of Private Equity

ADVANCED SEARCH: Discover more content by journal, author or time frame

  • Home
  • Current Issue
  • Past Issues
  • Videos
  • Submit an article
  • More
    • About JPE
    • Editorial Board
    • Published Ahead of Print (PAP)
  • Follow IIJ on LinkedIn
  • Follow IIJ on Twitter

Private Equity and Qualified Small Business Stock: Tax Implications of Various Holding Company Structures for Control Investments

Michael P. Spiro
The Journal of Private Equity Winter 2019, 23 (1) 10-29; DOI: https://doi.org/10.3905/jpe.2019.1.099
Michael P. Spiro
is a partner and chair of the tax group at the law firm of Finn Dixon & Herling LLP in Stamford, CT
  • Find this author on Google Scholar
  • Find this author on PubMed
  • Search for this author on this site
  • Article
  • Info & Metrics
  • PDF (Subscribers Only)
Loading

Click to login and read the full article.

Don’t have access? Click here to request a demo 
Alternatively, Call a member of the team to discuss membership options
US and Overseas: +1 646-931-9045
UK: 0207 139 1600

Abstract

In recent years, interest has grown in structuring private equity acquisitions to take advantage of the tax incentives associated with investments in qualified small business stock (QSBS). Although QSBS can often provide a meaningful tax benefit for private equity investors, deciding whether—and how—to structure a control investment for QSBS can be highly complex. This article considers the benefits of QSBS relative to investments in certain flow-through entities and explores several legal ambiguities and anomalies that lead to both planning opportunities and traps for the unwary in structuring platform investments and add-on acquisitions in a manner that optimizes QSBS.

TOPICS: Private equity, legal/regulatory/public policy, portfolio construction

Key Findings

  • • A description of the pre- and posttax IRR implications of an investment in QSBS.

  • • A discussion of the impact of management rollover on QSBS.

  • • Implications of various structures on the ability to maximize QSBS gain exclusion.

  • © 2019 Pageant Media Ltd
View Full Text

Don’t have access? Click here to request a demo

Alternatively, Call a member of the team to discuss membership options

US and Overseas: +1 646-931-9045

UK: 0207 139 1600

Log in using your username and password

Forgot your user name or password?
PreviousNext
Back to top

Explore our content to discover more relevant research

  • By topic
  • Across journals
  • From the experts
  • Monthly highlights
  • Special collections

In this issue

The Journal of Private Equity: 23 (1)
The Journal of Private Equity
Vol. 23, Issue 1
Winter 2019
  • Table of Contents
  • Index by author
  • Complete Issue (PDF)
Print
Download PDF
Article Alerts
Sign In to Email Alerts with your Email Address
Email Article

Thank you for your interest in spreading the word on The Journal of Private Equity.

NOTE: We only request your email address so that the person you are recommending the page to knows that you wanted them to see it, and that it is not junk mail. We do not capture any email address.

Enter multiple addresses on separate lines or separate them with commas.
Private Equity and Qualified Small Business Stock: Tax Implications of Various Holding Company Structures for Control Investments
(Your Name) has sent you a message from The Journal of Private Equity
(Your Name) thought you would like to see the The Journal of Private Equity web site.
CAPTCHA
This question is for testing whether or not you are a human visitor and to prevent automated spam submissions.
Citation Tools
Private Equity and Qualified Small Business Stock: Tax Implications of Various Holding Company Structures for Control Investments
Michael P. Spiro
The Journal of Private Equity Nov 2019, 23 (1) 10-29; DOI: 10.3905/jpe.2019.1.099

Citation Manager Formats

  • BibTeX
  • Bookends
  • EasyBib
  • EndNote (tagged)
  • EndNote 8 (xml)
  • Medlars
  • Mendeley
  • Papers
  • RefWorks Tagged
  • Ref Manager
  • RIS
  • Zotero
Save To My Folders
Share
Private Equity and Qualified Small Business Stock: Tax Implications of Various Holding Company Structures for Control Investments
Michael P. Spiro
The Journal of Private Equity Nov 2019, 23 (1) 10-29; DOI: 10.3905/jpe.2019.1.099
del.icio.us logo Digg logo Reddit logo Twitter logo Facebook logo Google logo LinkedIn logo Mendeley logo
Tweet Widget Facebook Like LinkedIn logo

Jump to section

  • Article
    • Abstract
    • REQUIREMENTS FOR QSBS4
    • QSBS VERSUS FLOW-THROUGH STRUCTURES: IRR CONSIDERATIONS AND GENERAL PARTNER CARRIED INTEREST
    • QSBS ACQUISITION STRUCTURES
    • CONCLUSION
    • ADDITIONAL READING
    • ENDNOTES
    • REFERENCES
  • Info & Metrics
  • PDF (Subscribers Only)
  • PDF (Subscribers Only)

Similar Articles

Cited By...

  • No citing articles found.
  • Google Scholar
LONDON
One London Wall, London, EC2Y 5EA
United Kingdom
+44 207 139 1600
 
NEW YORK
41 Madison Avenue, New York, NY 10010
USA
+1 646 931 9045
pm-research@pageantmedia.com
 

Stay Connected

  • Follow IIJ on LinkedIn
  • Follow IIJ on Twitter

MORE FROM PMR

  • Home
  • Awards
  • Investment Guides
  • Videos
  • About PMR

INFORMATION FOR

  • Academics
  • Agents
  • Authors
  • Content Usage Terms

GET INVOLVED

  • Advertise
  • Publish
  • Article Licensing
  • Contact Us
  • Subscribe Now
  • Log In
  • Update your profile
  • Give us your feedback

© 2022 Pageant Media Ltd | All Rights Reserved | ISSN: 1096-5572 | E-ISSN: 2168-8508

  • Site Map
  • Terms & Conditions
  • Privacy Policy
  • Cookies