$1.4M in federal tax avoided on a $42M exit through QSBS stacking
A second-time founder came to us 18 months before a strategic acquisition. Through QSBS qualification, non-grantor trust planning, and state-residency restructuring, we eliminated all federal tax on the qualifying portion.
- ▸The founder held 100% of his qualifying QSBS shares personally, capping the §1202 exclusion at $10M.
- ▸Florida residency was recent (12 months) — California was likely to assert source-tax jurisdiction.
- ▸Existing CPA had not modeled the AMT preference impact on the remaining gain.
QSBS stacking via non-grantor trusts
We established three irrevocable non-grantor trusts in a no-income-tax jurisdiction, each receiving QSBS shares before the LOI. Each trust qualified for its own $10M exclusion.
Residency hardening
Documented domicile via voter registration, driver's license, primary physician, and 183-day calendar. We pre-built the audit defense file before California could request it.
AMT and timing model
Built a multi-year projection across three close scenarios. Recommended accelerating $400K of charitable giving into the close year via a DAF.
- Federal tax on $40M of qualifying gain: $0.
- California source-tax claim withdrawn after our residency package.
- Founder reinvested $6M into a §1045 rollover — preserving QSBS treatment for the next venture.
"They walked into a meeting with my attorney and re-architected the deal in 90 minutes. The savings paid for 30 years of fees."
Could this be your story?
30-minute scoping call. Written proposal in one business day.
Book a Consult