In IRS Chief Counsel Memo 202204007, the IRS concluded that an online marketplace similar to AirBNB or Zillow that used its website to connect renters with tenants engaged in “brokerage service” for the purposes of Section 1202. That meant they were disqualified for the gain exclusion as Qualified Small Business Stock. What does this mean for other businesses, especially ones that act as intermediaries between third party businesses and their customers?
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