Under regulations prescribed by the Secretary, the basis of the purchasing corporations nonrecently purchased stock shall be the basis amount determined under subparagraph (B) of this paragraph if the purchasing corporation makes an election to recognize gain as if such stock were sold on the … See more The term recently purchased stock means any stock in the target corporation which is held by the purchasing corporation on the acquisition date and which was … See more The period referred to in subparagraph (A) shall also include any period during which the Secretary determines that there was in effect a plan to make a qualified … See more WebDec 13, 2011 · IRC Section 338 (h) (10) Gains for Sales Factor Purposes When a company has a gain from a deemed asset sale under IRC Section 338 (h) (10), a determination …
New York state tax gain from IRC § 338(h)(10) Deloitte US Tax
WebIn some situations, the deferred taxes of the acquired entity are affected not only by the change in tax status, but also by changes in the individual tax bases of its assets and … Web• Represented Peak Travel Group in the successful Stock Sale to Direct Travel, Inc. and advised Seller on IRC Section 338(h)(10) ramifications. fasting amazon
Earn-out Provision: The Hidden Tax Trap in a Sale of an S …
WebJul 19, 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 corporation or a corporation within a consolidated group to treat the transaction as an acquisition of 100% of the assets of the target for tax purposes. The … Web1.338(h)(10)-1(d)(4), the distribution of assets from a target to a seller prior to a transaction in which the parties made a valid election under IRC section 338(h)(10) election would be deemed to be included as part of a plan of liquidation. Treasury Regulation section 1.338(h)(10)-1(e), Example (2), describes a deemed liquidation WebI.R.C. § 338 (e) (1) In General — A purchasing corporation shall be treated as having made an election under this section with respect to any target corporation if, at any time during the … fast hungary szervíz