Other People's Money
Back to library
Loophole

§1202 QSBS Stacking via Non-Grantor Trusts

Multiply the $10M QSBS exclusion by gifting shares to multiple non-grantor trusts.

Overview

Before a QSBS liquidity event, gift blocks of qualified small-business stock to several non-grantor trusts (for children, spouse, dynasty). Each trust is its own taxpayer with its own $10M §1202 exclusion. Founders routinely turn a single $10M cap into $50M–$100M+ of tax-free gain — IRS-blessed when structured with independent trustees and real economic separation.

Best fit
C-corp founders pre-exitQSBS holders with >$10M expected gainEstate planners
Estimated impact
Extra $40M–$90M of federal-tax-free gain

Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.

More loophole strategies

See all Loophole strategies
OPM