338(h)(10) Structure: Pros, Cons for Sellers, Buyers | RKL LLP
https://www.rklcpa.com/338h10-transaction-structure-pros-cons-sellers-buyers/
WEBJun 18, 2019 · What is a 338 (h) (10) election? 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?
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