Data & Citations

Sources

Every claim on this site is backed by U.S. government data, peer-reviewed academic research, or official state records. Here are the primary sources.

Primary Data Source

U.S. Treasury OTA Working Paper 127 ↗

January 2025. Primary source for all distribution, claimant, and exclusion data (2012-2022). This paper from the Office of Tax Analysis provides the first comprehensive look at who claims QSBS, how often, and how much. Key findings: 75% one-time claimants, $2,810 median exclusion, 74% of claimants under $1M income.

Academic Studies

Edwards & Todenhaupt (2020) ↗

Study finding ~12% increase in startup investment after 100% QSBS exclusion. Uses within-firm funding round variation before/after the Small Business Jobs Act of 2010.

Chen & Farre-Mensa (2023/2025) ↗

Diff-in-diff study finding more firm births, startup employment, and first-round VC in QSBS-eligible industries after 2010 expansion to 100% exclusion.

Migration & Economic Data

IRS SOI Migration Data, 2021-2022 ↗

Interstate migration of tax filers and AGI. Shows net filer flows between states. See also: Tax Foundation analysis (Dec 2024) ↗

California Legislative Analyst's Office (2024) ↗

Analysis of high-earner outmigration and AGI losses from California, 2020-2022. $102 billion in AGI lost to outmigration. 24,670 high-earner households departed in 2022 alone.

Opposing Analysis

ITEP Section 1202 Analysis ↗

Source of the "94% goes to millionaires" claim. Provides state-by-state revenue estimates for QSBS decoupling. See our detailed analysis of this claim.

State Legislation

Methodology Notes

Income classification: All income brackets use Treasury's Total Positive Income (TPI) methodology, which excludes QSBS gains from income. This measures a claimant's regular economic income, not one-time liquidity events.

State conformity data: Compiled from state tax codes, legislative actions, and Tax Foundation analysis as of March 2026. "Pending" status indicates active legislation awaiting vote or signature.

Migration data: Based on IRS Statistics of Income (SOI) county-to-county migration data, tracking address changes on tax returns between filing years 2021 and 2022.

Calculator: Tax calculations use each state's top marginal capital gains tax rate. Actual tax liability may differ based on individual circumstances, filing status, and other state-specific rules.

Archetype examples: The four claimant archetypes (engineer, founder, employee, investor) are illustrative scenarios based on typical QSBS claim profiles described in Treasury data. Tax amounts calculated at California's 13.3% top rate.