What are the disadvantages of effecting a change in the basis of all the target’s assets either by their sale or by a stock purchase along with a Section 338(h) (10) election to treat the stock purchase as a purchase of all the firm’s assets?
Answer to relevant QuestionsWhat types of acquisitions of S corporations generate tax- deductible goodwill? How many acquisitions of S corporations, as a general rule, give rise to tax- deductible goodwill? The following facts relate to the purchase of an S corporation and a C corporation. These two corporations have identical tax bases and are similar in every respect except for their organizational form. The acquirer is ...What are the primary tax and nontax costs of a: a. Section 368 A tax- free reorganization b. Section 368 B tax- free reorganization c. Section 368 C tax- free reorganization d. Section 351 tax- free acquisition Why are tax-free subsidiary sales relatively uncommon? Under what circumstances is it more tax advantageous to give to charity during your lifetime rather than on bequest? What nontax factors might influence your decision?
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