CPA Consultant: S-Corp F-Reorg / QSub Continuation for QSBS C-Corp Structure

Job Overview We are an established corporate entity executing an F-reorganization and Qualified Subchapter S Subsidiary (QSub) drop via our legal tax team. The restructuring creates a new parent S-corporation holding company that will own a newly formed C-corporation subsidiary. This structure initiates the 5-year holding clock for Section 1202 Qualified Small Business Stock (QSBS). Our operating entity will become a disregarded entity but will retain its original EIN. Day-to-day operations, banking, and merchant processing will not change. We need an independent CPA consultant with direct experience in Section 368(a)(1)(F) restructurings. You will collaborate with our corporate law firm and our local tax preparer to oversee first-year transition compliance. Scope of Work & Responsibilities QSBS Structural Audit: Verify that the multi-step asset contribution to the C-corp subsidiary perfectly satisfies IRS Section 1202 "Original Issuance" rules. Form 8869 Compliance: Confirm the exact execution timing and filing windows for the QSub election. Continuous Tax Year Reporting: Guide our tax team on filing a single, continuing corporate Form 1120-S that seamlessly merges the entity transition data. Mid-Year Software Migration Review: Provide oversight for a mid-year payroll software migration (Paychex to Gusto) occurring on the same historical EIN. Required Qualifications Active Certified Public Accountant (CPA) license in the United States. Direct experience executing Section 368(a)(1)(F) S-corporation F-reorganizations. Deep technical understanding of Section 1202 QSBS original issuance frameworks. Experience interfacing with mid-market corporate transactional attorneys. Application Instructions Please submit a brief proposal summarizing your direct experience with F-reorganizations, QSub drops, and Section 1202 setups.