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We wound up doing the rest of the infusion in a different vein in my other arm. A few days later, I noticed pain and swelling in the vein the promethazine was given in. After a few more days, three lumps started forming in the vein, one quite large one (in picture 2), a smaller one above that, and another small one on my wrist bone. Redness (in picture 1) of surrounding skin also comes and goes. This issue has only been getting more swollen and painful over the past two months. I saw a NP for this today and she did an X-ray which showed nothing abnormal. She was concerned it may be a blood clot and I’m wondering if others agree. She wants me to get an ultrasound as well, but I can’t get in for this for some time. Para oyunu.
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. The planning opportunity afforded through the incorporation of a partnership arises out of the fact that for Section 1202 gain exclusion purposes, the tax basis of property contributed in exchange for QSBS is deemed to be the fair market value of the property at the time of contribution. If a partnership is incorporated, the enterprise value of the partnership’s business would generally be treated as the fair market value of the contributed property. So, if the owners of a business decide to operate a start-up through an LLC or limited partnership and incorporate the business only after the enterprise value has increased substantially, the 10X Basis Cap could substantially increase the owners’ aggregate gain exclusion. Section 1202 also provides that when appreciated property is contributed in exchange for QSBS, the difference between the tax basis of the property and its fair market value for Section 1202 purposes does not qualify for the gain exclusion when the QSBS is eventually sold. Here is an example of how the 10X Basis Cap works when a partnership is converted to a C corporation and QSBS is issued to the partners.
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