Arlington, VA : Tax Management Inc., -
1 online resource.
Tax management portfolios ; 788-3rd.
Formatted Contents Note
Detailed analysis. Introduction and background Qualified stock purchase Effects of a [section] 338(g) election on old target Effects of a [section] 338(g) election on new target The [section] 338(h)(10) election Section 336(e) The consistency rules International aspects of [section] 338 Miscellaneous issues Mechanics of elections Working papers.
"... analyzes in detail the elections under [section] 338(g) and [section] 338(h)(10), available when a purchasing corporation makes a "qualified stock purchase" of a target corporation. If an election is made, "old" target is treated as selling all of its assets to itself as "new" target, and "new" target is treated as purchasing those assets. "New target" has a fresh start for most federal income tax purposes, including a fair market value basis in its assets.
Authors: James T. Chudy, David Early-Hubelbank and Harsha Reddy, . Rev. ed. of: Stock purchases treated as asset acquisitions : section 338 / by James T. Chudy, Philip H. Spector and Sarah L. McGill. 1997. Published: Washington, D.C., 2006-2007.
Bibliography, etc. Note
Includes bibliographical references.
System Details Note
Mode of access: World Wide Web.
Available in Other Form
Print version: Chudy, James T., 1959- Stock purchases treated as asset acquisitions. Arlington, VA : Tax Management Inc., -