Practical legal guidance on QSBS (Section 1202), equity compensation, startup formation, financing, and Washington State tax issues for founders, investors, and startup employees.
IP26-645 kills the 9.9% income tax before it starts — but the capital gains excise tax under chapter 82.87 RCW survives. Here's what the initiative's actual text does, and the litigation it sets up.
In a stock-for-stock acquisition, your QSBS may survive under Section 1202(h)(4) — but with an exchange-date gain cap most shareholders don't know about.
Changing domicile out of Washington is proven with paper, not intentions. A phase-by-phase checklist — before the move, move week, first 90 days, and every year after — with the documentation to keep at each step.
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.
QSBS is a fact-intensive benefit. The IRS doesn't take your word for it. Here's what your documentation needs to cover.
IP26-645 submitted 511,408 signatures on July 2 — nearly double the requirement. What the repeal initiative does, the November 3 timeline, the two-year constitutional lock if it passes, 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.
Part-year residents face a two-part calculation under ESSB 6346 — and the $1M standard deduction prorates by income, not days. How §§406 and 315 actually work, with examples.
Julian Robertson's New York residency audit came down to just four disputed days and $26.7M. Here's why documentation, not legal arguments, wins residency cases—and what it means for Washington founders before the 2028 income tax.
