338 H 10 Election Form

338 H 10 Election Form - A section 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 1 338 h 10 1 b 3 or an S corporation shareholder or shareholders Who Must File Generally a purchasing corporation must file Form 8023 for the target

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 stock of an S

338 H 10 Election Form

338 H 10 Election Form

The Internal Revenue Code allows buyers and sellers of the stock of an S corporation to make a Section 338 (h) (10) election so that a qualified stock purchase will be treated as a deemed asset purchase for federal income tax purposes.

Complete only for a section 338 h 10 election or if target was a member of a consolidated group or a controlled foreign corporation CFC or had been a CFC within the preceding 5 years Check if Common Parent of Selling Consolidated Group Selling Affiliate S Corporation Shareholder or U S Shareholder is a foreign entity

Quick Guide To Section 338 H 10 Elections National Law Review

A section 338 h 10 election is made jointly by both the old target shareholders and the purchasing corporation Form 8883 must be used to make both types of section 338 elections Who Must File For elections under sections 338 g and 338 h 10 both the old target and the new target must file Form 8883 When and How To File

PPT TAX ISSUES TO CONSIDER IN COMMON ACQUISITION SCENARIOS PowerPoint Presentation ID 1231914

A section 338 h 10 election is made jointly by both the old target shareholders and the purchasing corporation Form 8883 must be used to make both types of section 338 elections Who Must File For elections under sections 338 g and 338 h 10 both the old target and the new target must file Form 8883 When and How To File

Span Class Result Type

In simple terms a 338 h 10 is a tax election for a qualified stock purchase QSP which recharacterizes a stock purchase as an asset purchase for federal tax purposes It remains a stock purchase for all other legal purposes such as contracts and licensing more on that later Why do buyers like it

Section 338 h 10 Election Archives Calder Capital LLC

Forms and Instructions About Form 8883 Asset Allocation Statement Under Section 338 Use Form 8883 to report information about transactions involving the deemed sale of corporate assets under section 338 This includes information previously reported on Form 8023 Elections Under Section 338 for Corporations Making Qualified Stock Purchases

Making the 338 (h) (10) Election A buyer and seller will sometimes make a 338 (h) (10) election, which treats an acquisition of a corporation's stock as a sale of assets for federal...

M A And Election To Treat Stock Acquisition As An Asset Acquisition

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 stock of an S corporation or a corporation within a consolidated group to treat the transaction as an acquisition of 100 of the assets of the target for tax purposes

338 H 10 Election Form

Forms and Instructions About Form 8883 Asset Allocation Statement Under Section 338 Use Form 8883 to report information about transactions involving the deemed sale of corporate assets under section 338 This includes information previously reported on Form 8023 Elections Under Section 338 for Corporations Making Qualified Stock Purchases

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 stock of an S

Mack Moran CFA CPA On LinkedIn F Reorganization Or 338 h 10 Election Choose The Less