Partnership distribution of QSBS to another partnership

Technical topics regarding tax preparation.
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Can QSBS be transferred from a partnership to another partnership and to an individual and retain the QSBS treatment? I think so based on Section 1202(h)(2)(C). Basically, we are trying to inject another partnership between a partnership and an individual; the partnership holds and often acquires QSBS stock. I think this would only work on new QSBS acquisitions after the new owners come in. Does that make sense?


Section 1202(h)(2)(C) provides that a transferee of QSBS from a partnership to a partner may result in the partner being treated as having acquired the QSBS in the same manner as the partnership, including stepping into the partnership’s holding period. This beneficial treatment is available only to the extent that the partner held an interest on the date the QSBS was acquired by the partnership and then only to the extent of such interest.
 

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