Question

What does QSBS stacking do under The One Big Beautiful Bill Act (OBBBA) rules?

Answer

Qualified small business stock (QSBS) stacking multiplies the Section 1202 gain exclusion by gifting qualified shares to multiple nongrantor trusts, each of which qualifies as a separate taxpayer for the exclusion. For stock issued after July 4, 2025, each taxpayer may exclude up to $15 million. A founder who stacks across several trusts may shelter more gain than the individual cap allows. This strategy requires proper trust structure and timing before a signed letter of intent or initial public offering (IPO).

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