Updated July 28, 2026. Quick answer: The per-issuer cap is the greater of the dollar amount — $15,000,000 for stock issued after 4 July 2025, $10,000,000 for earlier stock — or ten times your aggregate adjusted basis in that issuer’s stock (IRC §1202(b)(1)).
Two limits, and you get the larger
The dollar cap is what everyone quotes. The 10× basis alternative is what actually governs for anyone who paid meaningful money for the shares.
| Your basis | 10× basis | Cap if issued after 4 Jul 2025 |
|---|---|---|
| $1,000 (founder) | $10,000 | $15,000,000 — dollar cap governs |
| $250,000 | $2,500,000 | $15,000,000 — dollar cap governs |
| $2,000,000 (investor) | $20,000,000 | $20,000,000 — basis governs |
Per issuer, not per lifetime
The cap applies separately to each qualifying issuer. Someone holding QSBS in three different companies has three separate caps. This is the most commonly misunderstood feature of the provision and it materially changes planning for angel investors.
The dollar figures are indexed for inflation beginning in 2027, so the $15,000,000 will drift upward. The 10× basis multiple is not indexed — it does not need to be, since basis is already in current dollars.
Sources
IRC §1202(a)(5) (tiered exclusion); IRC §1202(b)(1) (10x basis alternative); new IRC §1202(b)(4) ($15,000,000 cap and inflation indexing from 2027); One Big Beautiful Bill Act, enacted 4 July 2025. Cross-checked against professional analyses from The Tax Adviser (AICPA), Baker Tilly, Holland & Knight, K&L Gates, Mintz, Davis Wright Tremaine and Grant Thornton, July–November 2025.
This states what the cited authority says. It is not tax advice, and Section 1202 qualification turns on facts about the issuing company that no page can verify for you.