WebJul 26, 2016 · Section 338(h)(10) of the Internal Revenue Code can provide significant tax benefits to a buyer of 80% or more of a target corporation. A 338(h)(10) election allows a buyer of stock of an S corporat WebApr 7, 2015 · A Section 336(e) election combines substantially similar tax consequences as a Section 338(h)(10) election (i.e., a step-up in the tax basis of the target corporation’s assets) with a simpler ...

336 - U.S. Code Title 26. Internal Revenue Code - Findlaw

WebA primary purpose of IRC 367(b) is to ensure that previously deferred foreign earnings of a FC do not escape U.S. taxation at ordinary rates through non-recognition transac tions. In … Webaspect of section 336, the Internal Revenue Service (IRS) has attempted to override section 336 by application of other theories such as the tax benefit rule.2' For example, in … shane wilson nascar truck series

Section 1202: A Big Deal for Small Business - American Bar …

WebIf in connection with an applicable asset acquisition, the transferee and transferor agree in writing as to the allocation of any consideration, or as to the fair market value of any of the assets, such agreement shall be binding on both the transferee and transferor unless the Secretary determines that such allocation (or fair market value) is … WebIf a shareholder in an S corporation terminates his or her entire interest in the corporation, 1377(a)(2) permits the corporation to elect to have the 1377(a)(1) rules applied as if the taxable year consisted of two taxable years. The first … Webfor purposes of this section and section 336, any transfer of property to the 80-percent distributee in satisfaction of such indebtedness shall be treated as a distribution to such distributee in such liquidation. (2) Treatment of tax-exempt distributee (A) In general shane windsor