Page 3
In PLR 201636003 the IRS ruled that stock can be QSBS without formal stock certificates — ownership is a matter of economic substance. Here's what the ruling holds, and what it carefully didn't decide.
Let's Go Washington reported 511,408 submitted signatures on July 2; the Secretary of State counted 509,365 petition lines and certified Initiative 645 by sample (12,936 of 15,281). What repeal would change — and why founders should keep planning as if the 9.9% tax takes effect.
Washington's 30-day safe harbor makes you a nonresident — it doesn't change your domicile. Long-term stock gains are allocated by domicile at the time of sale, so the safe harbor alone won't protect your exit.
How Washington’s part-year income and deduction rules work, with two calculations and the residency issue raised by retaining a Washington home.
The Robertson residency dispute illustrates why day counts and supporting evidence deserve attention when planning a move.
Initiative 645 is certified for the November 3, 2026 ballot — but the 9.9% tax remains law, effective January 1, 2028. The planning playbook for Washington founders, investors, and high earners.
Separate the QSBS gross-assets test, contributed-property FMV rules, shareholder basis and eligible-gain limit—with a worked example of pre-contribution appreciation.
A SAFE side letter can provide QSBS information rights and annual factual certifications. It cannot settle the SAFE’s tax classification or guarantee a Section 1202 exclusion.
Company and shareholder records that support Section 1202 eligibility: formation, issuances, gross assets, active business, redemptions, and holder-level history.
