Websection 338(h)(10) election cannot be made for a target corporation unless it is acquired from a selling consolidated group, a selling affiliate (as defined in Regulations section … WebA §338(h)(10) Election is made jointly by the seller and purchaser and is available only when the target is a subsidiary member of the consolidated or affiliated group or is a S …

Instructions for Form 8023 (11/2024) Internal Revenue …

WebSection 338 (h) (10) Election Scenario 1 You’ve found a great company whose acquisition you believe would advance your objectives. Its stock is valued at $1.5 million. But then … 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 ... fish and chips japan

Automatic relief available for some missed elections Crowe LLP

Webdistributions, loss limitation rules, and the effect and advisability of making a Section 338(h)(10) election or a Section 336(e) election to treat the sale of stock as an asset sale. There is also the much wider world of Subchapter … WebAug 5, 2010 · Section 338(h)(10) Election – Basic Requirements Qualified Stock Purchase àAcquiring must be a corporation (can be newly formed but not transitory) àTarget must be a domestic corporation (S Corporation or C Corporation subsidiary in affiliated group) àAcquiring must “purchase” the Target stock (generally means a taxable transaction) WebOct 5, 2015 · But not any old corporation will do; rather, a Section 338 (h) (10) election is limited to the stock purchase of three specific types of corporate targets, all of which … camshaft intake actuator solenoid