July 6, 2026
Foley Viewpoints
QSBS Trust Stacking Comes Under the Microscope
First enacted in 1993, Qualified Small Business Stock (QSBS) has been one of the most powerful wealth-building tools for founders, early employees, and venture investors. Section 1202 of the Internal Revenue Code allows up to $15 million in capital gains to be shielded from federal taxes on the sale of qualifying stock, provided the stock is held long enough and the company meets the statutory requirements. That benefit became even more valuable after Congress expanded the exclusion in 2025.