338 H 10

Oct 14, 11
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  • A §338(h)(10) Election is made jointly by the seller and purchaser and is . A § 338(h)(10) Election avoids the shareholder-level tax by treating the target as .
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  • Feb 9, 2009 – Let me clarify something on 338(h)(10) election provision. My understanding is that if an m&a deal is eligible for the provision, "goodwill" will be .
  • Apr 9, 2010 – In order to make a 338 election, must an acquirer be a c-corporation? If not, what are the limitations regarding the acquiring entity's legal .
  • In recent research, "The Effect of Transaction Structure on Price: Evidence from Subsidiary Sales," Erickson analyzes the effects of the IRC §338(h)(10) election .
  • If a section 338(h)(10) election is made for the target, the target generally is treated as making the deemed sale and liquidating. The treatment of the target .
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  • In a section 338(h)(10) election, the transaction is treated as an asset purchase for tax purposes. Ownership of the assets continues with the target corporation. .
  • From a technical standpoint, the 338(h)(10) election causes the target to be . A purchaser benefits from a 338(h)(10) election if the stock purchase price is .
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  • A section 338(h)(10) election may be made for T if P acquires stock meeting the . The section 338(h)(10) election must be made not later than the 15th day of .
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  • Section 338(h)(10) Election . In General . Under the pre-1986 version of § 338, a corporation that sold the target's stock (the seller) was granted an election (a .
  • Sep 28, 2010 – Taxpayers and advisors should give careful consideration to .
  • Foreign targets are not eligible for the 338(h)(10) election, but are eligible for the 338(g) . To qualify for a 338(h)(10) election, the target must be either 1) a U.S. .
  • 338(h)(10), whereby the selling shareholders are permitted to join with the purchasing corporation . Does the election under 338(h)(10) yield the best results? .
  • In this instance, however, the purchasers and sellers of the SBS stock made a valid election under Internal Revenue Code section 338(h)(10). Under this .
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  • May 8, 2008 – If so, the tax basis of its assets may be revalued through the use of an IRC Section 338(g) or 338(h)(10), or an IRC Section 754 election in the .
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  • Section 338(h)(10) of the Internal Revenue Code doesn't sound like the title for a work of fiction, but a fiction is what it creates. When selling or buying a bank .
  • WST: 13.3 M&A Deal Structuring - 338(h)(10) Elections - YouTube Jul 8, 2008 - 7 min - Uploaded by wstss
  • Aug 7, 2003 – A Section 338(h)(10) election allows a purchasing corporation to treat its . The parties to a transaction may generally make a 338(h)(10) .
  • The purpose of this information release is to explain how making the Internal Revenue Code (IRC) section 338(h)(10) election impacts the Ohio corporation .
  • If a section 338(h)(10) election is made, the tax cost of increasing the basis of Target's . However, selling groups will agree to enter into the section 338(h)(10) .
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  • 4 posts - 2 authors - Last post: Aug 28, 2008Why would a seller be motivated to do a 338(h)10 since they would be taxed twice, since the 338(h)10 treats the sale as an asset sale, vs. only .
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  • 338(h)(10) always respected in stock and asset purchases? . 338(h)(10) of the federal Tax Code, parties involved in a qualified stock purchase can execute a .
  • This digital document is an article from The Tax Adviser, published by American Institute of CPA's on February 1, 1995. The length of the article is 5921 words. .
  • A Section 338(h)(10) election is jointly made by the purchasing corporation and the common parent of the selling consolidated group (or the selling affiliate or .
  • 338. Certain stock purchases treated as asset acquisitions. How Current is This? . . (h) Definitions and special rules . . Except as otherwise provided in paragraph (10) or in regulations prescribed under this paragraph, the target corporation .
  • Question - For S-corps under section 338(h)(10) why is it said that the. Find the answer to this and other Tax questions on JustAnswer.
  • 9 posts - 6 authors - Last post: Feb 9, 2010The C corp has a bunch of NOL so I think it makes sense to make a 338(h)(10). My question is whether the 338 election is permissible when an .
  • As a general rule, buyers prefer to purchase the assets of a corporate business. One of the principal nontax reasons for buying assets (as opposed to the stock) .
  • Mar 31, 2011 – Title: Increased Opportunities for Sec. 338(h)(10) Elections. Article: The Small Business Jobs Act changes the S corporation built-in gains (BIG) .
  • USA An election to treat a stock acquisition of the target corporation generally as an asset acquisition for US federal income tax purposes. A buyer may want to .

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