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Because of Section 351, this conversion will not be a taxable event. Step 3: At the time of conversion, the tax basis is equal to the FMV of the interest held in the LLC that is exchanged for ownership in the C-Corp. /rabbits is an open casino pimp community where users can learn, share cute pictures, or ask questions about rabbits. At the time of conversion, the fair market value of the LLC that is being contributed to the C-Corp will be $15M (assumed pre-money valuation). FMV for a startup can be very close to the pre-money valuation in 409a analysis, that I used to do in my past life. Step 4: After five years and three months, when I sell my company, my QSBS exemption will be $150M (10X of $15M) I will reach out to a tax advisor before incorporating my company as the prospect of dramatically increasing the QSBS exemption is very tempting. But I want to hear any thoughts people may have on this. Feel free to poke holes or ask questions. Thank you for your help! ​ Background research: Per this article (https://frostbrowntodd.com/maximizing-the-section-1202-gain-exclusion-amount/), the LLC to C-Corp conversion allows the QSBS exemption to be as high as $500M. With my wife’s breathtaking beauty, not even the newly enthroned empress can match her! With my wife’s marvelous culinary skills, not even the empress’s royal chefs can match her! My wife loves me and cares about me very very much, and I wouldn’t trade her for even the empress! Wait, what? My wife is the empress?! My Wife Is Actually The Emperor / My Wife Is Actually The Empress casino pimp manhua . This creates a potential planning opportunity involving operating a start-up as a partnership for several years and then incorporating the partnership and in the process, issuing QSBS to the partners in exchange for their partnership interests. Both a partnership’s assets and partnership interests qualify as a property that can be contributed by a partnership or LLC to a C corporation (generally in a Section 351 exchange) in exchange for QSBS.