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... Web3. T’s shareholders have basis in T stock=$120. 4. A makes a Sec. 338 election. To make 338 election must have: 1. 2. Taxes and Business Strategy Merle Erickson Page 24Result: (Do T shareholders first) T shareholders (first): • Receive $179 from the Acquirer • Recognize a gain = • Pay tax = • After-tax, shareholders have.

Increased Opportunities for Sec. 338(h)(10) Elections

WebMar 13, 2009 · An election under section 338 (h) (10) of the Internal Revenue Code is often used to characterize the sale of stock of an S corporation as a deemed sale of all of the … WebFor the parties to make a Sec. 338 (h) (10) election in the S corporation context, the acquiring corporation must acquire domestic S corporation stock in a qualified stock … josh toner st pete beach

Section 338 (Portfolio 788) - Bloomberg Tax

Webmaking a § 338(h)(10) election for the target corporation, a C corporation, which is either the corporate shareholder’s affiliate or a member of its consolidated gr oup? A-4: The corporate shareholder recognizes no gain or loss on the sale of the target corporation’s stock. See § 1.338(h)(10)-1T(d)(5)(iii) of the temporary Income Tax ... WebSection C—Common Parent of Selling Consolidated Group, Selling Affiliate, S Corporation Shareholder, or U.S. Shareholder . Complete only for a section 338(h)(10) election or if … WebSep 1, 2024 · An election under Sec. 338 (h) (10) or Sec. 336 (e) provides a buyer of corporate stock the convenience of a stock purchase with the tax benefits of an asset acquisition; however, each election has its own requirements and limitations. how to link origin account to steam