Section 1202 Updates: Understanding QSBS Tax Benefits

Qualified Small Business Stock (QSBS) under Section 1202 may allow business owners, founders and investors to exclude a significant portion of capital gains from federal taxable income when selling qualifying stock.

In this episode of Cherry Bekaert’s Tax Beat podcast, we are joined by the Firm’s National Tax Practice Leader, Michael Wronsky, Tax Directors Sarah McGregor and Barry Weins, and Transaction Tax Manager Molly Gill. Our tax professionals discuss recent Section 1202 updates, key eligibility requirements and planning opportunities for growing businesses.

Listen to learn more about:

• Core QSBS qualification requirements, including C corporation status, gross asset limits, the 80% active business test and shareholder eligibility
• Recent Section 1202 changes, including tiered holding periods and expanded gain exclusion opportunities
• Tax planning considerations for partnerships and S corporations evaluating a conversion to C corporation status
• Common QSBS pitfalls, such as stock redemptions, excess working capital, corporate investment and valuation challenges that may impact eligibility

Recent court decisions are prompting renewed discussion around how disaster relief provisions apply to Internal Revenue Service (IRS) deadlines and what actions taxpayers may take before key limitation periods expire.

The federally declared COVID-19 disaster period may have created unexpected opportunities for taxpayers to revisit penalties, interest assessments and refund claims tied to prior tax filings and payments.

In this episode, Michael Wronsky, Managing Director and Leader of Cherry Bekaert’s National Tax Practice, and Sarah McGregor, Tax Director, discuss taxpayer-favorable court rulings and the broader implications for businesses and individuals that incurred penalties or interest during the pandemic years. They explain how these cases could impact filing deadlines, refund opportunities and IRS procedures, while also addressing the uncertainty created by ongoing government appeals and evolving guidance.

Listen to learn more about:

• 01:18 – Background on recent taxpayer-favorable court cases
• 02:45 – Impact of disaster relief provisions on tax deadlines during the COVID-19 pandemic
• 05:00 – Factors that resulted in an unusually long postponement period
• 06:07 – Potential opportunities related to penalties and interest assessments
• 08:15 – Protective refund claims and abatement considerations
• 09:40 – The IRS response and pending litigation
• 12:20 – Key timing considerations and statute of limitations concerns
• 15:00 – Practical next steps for taxpayers and advisors

2025 tax law changes are reshaping depreciation, energy incentives and cash‑flow planning

In this episode of the Tax Beat Podcast, Cherry Bekaert tax professionals explore recent developments benefiting cost segregation studies, the Section 179D Energy Efficient Commercial Buildings deduction (Section 179D), and bonus depreciation. Their discussion explains how these incentives help commercial real estate owners and capital‑intensive businesses accelerate deductions by shifting depreciation into earlier tax years — improving cash flow and supporting expansion, renovation and new construction projects.

Key Topics Discussed

• Cost segregation fundamentals and accelerated depreciation
• Permanent 100% bonus depreciation and planning considerations
• QPP for manufacturers
• Section 179D basics and eligibility
• Section 179D opportunities for designers and tax‑exempt buildings
• Retroactive planning opportunities
• Construction timing and upcoming Section 179D deadlines
• Coordinating multiple tax incentives for maximum benefit

The panel covers how the return of permanent, 100% bonus depreciation has renewed interest in cost segregation studies, and how manufacturers may benefit from the newly enhanced Qualified Production Property (QPP) rules. The conversation ends with an emphasis on the value of a coordinated, full‑service approach to identifying and stacking multiple tax incentives while managing compliance and risk.

Listen now to learn how cost segregation and Section 179D can work together to accelerate deductions, improve cash flow and help businesses adapt their tax strategies amid evolving legislation.

As cross-border activity becomes increasingly common for middle-market companies, international tax considerations are no longer limited to large multinationals. From transfer pricing and tariffs to global tax compliance and planning, businesses expanding overseas face greater complexity and heightened scrutiny from tax authorities worldwide. Understanding where value is created, how intercompany transactions should be priced, and how global tax rules interact is critical for managing risk and supporting sustainable international growth.

In this episode, Brooks Nelson, Tax Partner, and Sarah McGregor, Tax Director, are joined by Nelson Yates, Partner and International Tax Leader, to discuss key cross-border tax issues middle-market CFOs and business leaders should have on their radar. They break down transfer pricing fundamentals, explore how tariffs intersect with intercompany pricing, and share practical considerations for companies entering or expanding in foreign markets.

Listen to learn more about:

• 02:30 – Transfer pricing basics and why it matters
• 04:10 – How governments view cross-border profit allocation
• 06:27 – Intercompany services, IP, and value drivers
• 10:38 – Marketing intangibles and local market investment
• 11:55 – Practical steps CFOs can take today
• 14:45 – Transfer pricing documentation and penalty protection
• 16:35 – Tariffs and their interaction with transfer pricing
• 20:20 – Global tax planning and compliance implications
• 22:42 – International expansion costs and best practices

Related Guidance

• Article: Navigating the International Tax Landscape After 2025 Tax Reform

Stay informed on the latest tax policy changes and economic trends with Cherry Bekaert’s Tax Beat Podcast. In this episode, hosts Brooks Nelson, Tax Partner, and Sarah McGregor, Tax Director, talk with Kasey Pittman, Managing Director of Tax Policy, about the sweeping P.L. 119-21, or the “One Big Beautiful Bill Act.” They also discuss Internal Revenue Service (IRS) guidance and what businesses and individuals need to know heading into 2026.

In This Episode:

• 2025 Tax Reform Explained: $4.5 trillion in tax cuts and key provisions for taxpayers
• Government Shutdown Effects: IRS operations, filing season delays and electronic payment changes
• Economic Outlook: Interest rate trends, inflation risks and planning opportunities
• Legislation Watch: Cryptocurrency tax rules, tax extenders and bipartisan bills

Discover actionable insights to navigate uncertainty, optimize tax planning and prepare for upcoming changes in legislation and economic conditions.

Connect With Us

Related Through Leadership

• Newsletter: Tax Policy Review: November 2025 Updates
• Alert: 2025 Government Shutdown FAQs: What To Expect in the Second Week
• Webinar Recording: Beyond the Bill: Tax Insights for the 2025 Reform
• Article: Tracking Tax Reform: A Closer Look at the Final 2025 Budget Reconciliation Bill

As we navigate through changes brought by the new administration in 2025, there are significant developments within the Internal Revenue Service (IRS) that will impact taxpayers and tax professionals. The IRS is aiming to streamline its operations while facing the challenge of reduced staffing levels. With proposed federal workforce reductions and shifts in technology modernization efforts, understanding how these developments will affect IRS operations is crucial for maintaining compliance and efficiency in tax practices.

In this episode, Brooks Nelson, Partner and Strategic Tax Leader, and Sarah McGregor, Tax Director, are joined by Ron Wainwright, Tax Partner, and Kasey Pittman, Tax Managing Director. Together, they delve into the announced changes to the IRS workforce, discuss potential impacts on taxpayers and explore the ongoing technological transformations within the agency.

Listen to learn more about:

• 02:02 – IRS workforce reductions
• 05:02 – Changes in IRS leadership
• 08:39 – IRS Priority Guidance Plan
• 12:33 – Technology modernization
• 17:19 – Impact on taxpayers
• 19:12 – Taxpayer assistance proposal
• 22:14 – Best practices with the IRS

Related Guidance

• Article: Tracking Tax Reform: The Reconciliation Process
• Article: Recent IRS Guidance for the Definition of Employee
• Article: IRS Issues Final Regulations Impacting Micro-Captive Insurance Arrangements
• Article: IRS Guidance for Theft Losses From Online Scams
• Webinar Recording: Clean Energy Incentives, Prevailing Wage & Apprenticeship: IRS Insights

Earlier this year, final regulations were issued under Prop. Reg. Section 1.6011-10, setting forth the criteria that classify certain micro-captive insurance arrangements as listed transactions or transactions of interest. These designations require extensive tax return disclosures and impact all parties, including related entities.

As micro-captives continue to be a focal point for Internal Revenue Service (IRS) enforcement, understanding these regulations is crucial for businesses aiming to maintain compliance and avoid potential penalties. Micro-captive insurance arrangements have long been a topic of concern for the IRS due to their potential for abuse in tax planning. The recent regulations aim to address these concerns by providing clear guidance on what constitutes a reportable transaction.

In this episode, Brooks Nelson, Partner and Strategic Tax Leader, and Sarah McGregor, Tax Director, are joined by Rick Woods, Tax Partner. Together, they dive into the implications of these regulations, discuss IRS enforcement efforts and explore what constitutes a listed transaction versus a transaction of interest.

Listen to learn more about:

• 04:11 – IRS interest in micro-captives
• 06:01 – Section 831(b) in micro-captives
• 08:29 – IRS history with micro-captives
• 11:48 – Criteria for micro-captive transactions
• 17:13 – Reporting micro-captive transactions
• 19:49 – Exceptions in micro-captive coverage
• 21:24 – Exiting micro-captive arrangements
• 22:37 – Economic reasons for micro-captives
• 24:30 – Risk management in micro-captives

Related Guidance

• Article: IRS Issues Final Regulations Impacting Micro-Captive Insurance Arrangements

Navigating the complex terrain of financial statement reporting and income tax disclosures is a major challenge for companies as they face heightened regulatory scrutiny and evolving standards. The Financial Accounting Standards Board (FASB) continues to introduce significant updates, including ASU 2023-09, which requires greater transparency and more detailed reporting of tax provisions. These changes reshape how companies present their tax positions within financial statements, emphasizing the need for robust systems and strategies to manage increased disclosure requirements.

As organizations continue adapting to these standards in 2025, understanding tax provisions and their implications remains essential for maintaining compliance and demonstrating financial integrity.

In this episode, Brooks Nelson, Partner and Strategic Tax Leader and Sarah McGregor, Tax Director, are joined by William Billips, Tax Partner, and Lisa Macri, Tax Director. Together, they explore key tax legislation updates from 2024 and strategies for navigating the road ahead. This discussion is crucial for finance professionals seeking to build on last year’s adjustments and ensure their organizations remain prepared for the evolving landscape of tax reporting.

Listen to learn more about:

• 03:30 – Understanding ASC 740
• 04:25 – Common challenges with ASC 740
• 05:44 – Upcoming changes with ASU 2023-09
• 07:21 – Rate reconciliation and disaggregation requirements
• 08:33 – Preparing for ASU 2023-09 implementation
• 09:32 – Transferability of energy credits
• 10:45 – Acquisitions and dispositions key considerations
• 11:50 – Pass-through entities and tax reporting
• 14:20 – Anticipating future tax law changes
• 16:37 – Planning for legislative changes

Related Guidance

• Newsletter: The Rundown: Fourth Quarter 2024 Guide
• Article: Unlocking Opportunities: The Evolving Market for Clean Energy Tax Credits