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On April 9, 2021, the IRS released Private Letter Ruling (PLR) 202114002 (January 13, 2021), which provides additional context to taxpayers worried about whether their Fintech or Insurtech shares represent Qualified Small Business Stock (QSBS) under Internal Revenue Code (IRC) section 1202. PLR 202114002 suggests that a Fintech or Insurtech company that conducts "administrative services beyond those that would be performed by a mere intermediary facilitating a transaction between two parties" would not be considered engaged in "brokerage services" for purposes of IRC section 1202(e)(3)(A). More importantly, PLR 202114002 helps confirm that as long as the company does not fall under the definition of a bank or an insurance company, it does not appear to be engaged in any "banking," "insurance," or "similar business" for purposes of IRC section 1202(e)(3)(B).

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