If T is a C corporation, a Sec. 338 election is available; if T is an S corporation or

IRC 338(h)(10) - Elective Recognition of Gain or Loss by Target Corporation . .

In addition, the 1994 regulations allow the election to be made for the sale of

From a technical standpoint, the 338(h)(10) election causes the target to be

The 338(h)(10) election is not applicable where an S Corporation holding

Section 338(h)(10) S Corporation Checklist (Rev. 9/05). PREFACE. When the

Apr 1, 2006 . How do I figure the tax effect of selling my Subchapter S Corp? . This election is

338(h)(10) elections involving S corporation targets.: An article from: The Tax

Section 338(h)(10) Election. In a transaction involving a stock purchase of an S

A Section 338(h)(10) election may be made for a target corporation if a . affiliate

Buying an S corporation? Use a 338(h)(10) election by Robert Willens In

May 8, 2008 . Legal Status of Target — Is the acquired entity an S Corp, LLC or Partnership? .

(b) Section 338(h)(10) elections for S corporation targets. The requirements of §§

I am having problems finding information on S-Corp shareholder's treatment

corporations, to the end that taxable income reported each taxable year by a

If you ever do purchase an S corporation, you want to know about something

Aug 28, 2008 . Are sellers that are structured as a LLC, S-Corp, LLP more inclined to accept a

S Corp Target shareholders must consent to 338(h)(10) election. ∎. Sellers may

Feb 1, 1995 . In early 1994, the Treasury issued regulations under Sec. 338(h)(10) that

sell your company via a sale of assets, a sale of stock, or, if you have an. S-

Sep 28, 2010 . While I.R.C. § 338(h)(10) elections typically provide federal tax benefits for the

Mar 31, 2011 . Title: Increased Opportunities for Sec. 338(h)(10) Elections. Article: The Small

A Three-Step Process. There are three steps to making a Section 338(h)(10)

Corporation's business assets and or a sale of all of the S-Corporation's stock

Aug 23, 2011 . A special election is available to S Corporations under Internal Revenue Code §

Aug 7, 2003 . A Section 338(h)(10) election allows a purchasing corporation to treat its

If a section 338(h)(10) election is made, the tax cost of increasing the basis of .

Jan 14, 2008 . Can anyone point me to guidance on preparing an S Corporation final part-year

New York Section 338(h)(10) Elections on the Sale of S Corporation Stock.

Does Georgia recognize Internal Revenue Code Section 338(h)(10) elections by

shareholders, of stock in an S corporation where an election has been made

Mar 19, 2009 . Code Section 338(h)(10) – Additional. Issues. ∎ Stock Basis vs. Inside Asset

corporation was not recognized under the Georgia income tax laws because the

If the target is an S corporation, a section 338(h)(10) election must be made by all

when planning for the sale of the S corporation. Alternatives include a “deemed

an S corporation, and the PEF must form an acquisition corporation to acquire at

S corporation stock for GIT purpos- es—this time in the context of an. I.R.C.

S Corporation Shareholder, or U.S.Shareholder . 6 Check here to make a

Those thinking about selling an S Corporation should take into consideration the

TAX STRATEGIES FOR CORPORATE ACQUISITIONS,. DISPOSITIONS . .. In the

the 338 rules apply, including the IRC §338(h)(10) rules and their application to S

338(h)(10). The balance sheet of Target Corp. as of Sept. 30, 2003 reflected the

One particular provision of the tax code, known as a Section 338(h)(10) election,

group, selling affiliate or S corporation shareholders) ("S") may make a joint

Nov 14, 2011 . With respect to the S corporation and taxes, especially where a 338(h)10 election

Continuation of S Corporation and QSub Status. e. Tiered Targets. 3. Deemed

Taxable Acquisitions of S Corporations (or of Certain Subsidiaries in Affiliated

A section 338(h)(10) election is made jointly by P and the selling consolidated

Section 338(h)(10) Election. This election applies to acquisitions of corporate

Jun 27, 2011 . Regulations endorse the use of the installment sale method for section 338(h)(10

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