Keyword Analysis & Research: 338 h 10


Keyword Analysis

Keyword CPC PCC Volume Score Length of keyword
338 h 101.830.36022358
3380.710.3371493
h0.670.548761001
101.650.92920472

Keyword Research: People who searched 338 h 10 also searched

Keyword CPC PCC Volume Score
338 h 100.960.6168170

Search Results related to 338 h 10 on Search Engine

  • 338(h)(10) Structure: Pros, Cons for Sellers, Buyers | RKL LLP

    rklcpa.com

    https://www.rklcpa.com/338h10-transaction-structure-pros-cons-sellers-buyers/

    WEBJun 18, 2019 · 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).

    DA: 11 PA: 96 MOZ Rank: 33

  • Quick Guide to Section 338(h)(10) Elections - National Law Review

    natlawreview.com

    https://www.natlawreview.com/article/quick-guide-to-section-338h10-elections

    WEBJul 26, 2016 · 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...

    DA: 30 PA: 5 MOZ Rank: 59

  • Section 338(h)(10) Election - The Unicorn of M&A - Leo Berwick

    leoberwick.com

    https://www.leoberwick.com/338h10-election/

    WEBThe buyer and the seller jointly make a 338 (h) (10) election. With this election, the buyer purchases the stock, which allows the target company to maintain non-transferrable assets (e.g. contracts) and remain a separate entity from a legal standpoint.

    DA: 87 PA: 92 MOZ Rank: 40

  • Tax Geek Tuesday: A Buyer's Best Friend - Understanding The Section 338

    forbes.com

    https://www.forbes.com/sites/anthonynitti/2015/10/05/tax-geek-tuesday-a-buyers-best-friend-understanding-the-section-338h10-election/

    WEBOct 5, 2015 · A Section 338(h)(10) election allows an electing buyer (P) and seller (T) to treat P as having purchased T's assets for tax purposes, even though P purchased T's stock for legal purposes.

    DA: 90 PA: 1 MOZ Rank: 69

  • 26 U.S. Code § 338 - Certain stock purchases treated as asset

    cornell.edu

    https://www.law.cornell.edu/uscode/text/26/338

    WEB“The amendment made by subparagraph (A) [amending this section] shall apply to qualified stock purchases (as defined in section 338(d)(3) of the 1986 Code) after March 31, 1988, except that, in the case of an election under section 338(h)(10) of the 1986 Code, such amendment shall apply to qualified stock purchases (as so defined) after June ...

    DA: 4 PA: 55 MOZ Rank: 64


  • M&A and Election to Treat Stock Acquisition as an Asset Acquisition

    bloombergtax.com

    https://news.bloombergtax.com/tax-insights-and-commentary/m-a-and-election-to-treat-stock-acquisition-as-an-asset-acquisition

    WEBJun 9, 2022 · A Section 338(h)(10) election is a joint election that requires agreement between and among all of the selling shareholders and the prospective buyer. As a result of this election, a stock sale for legal purposes will be treated as an asset sale for tax purposes, resulting in different tax consequences for both the buyer and seller that selling ...

    DA: 74 PA: 97 MOZ Rank: 65

  • Avoid the Surprise: Know Your IRC Section 338(h)(10) State …

    alvarezandmarsal.com

    https://www.alvarezandmarsal.com/insights/avoid-surprise-know-your-irc-section-338h10-state-rules

    WEBDec 13, 2011 · An IRC Section 338 (h) (10) election is available when one corporation is purchasing the stock of either an S corporation or a C corporation that is a member of an affiliated group of corporations. Generally, the consequences of the election are that the sale of stock is disregarded and treated as a deemed asset sale for income tax purposes.

    DA: 8 PA: 61 MOZ Rank: 75

  • GT’s Quick Guide to Section 338 (h) (10) Elections | Insights

    gtlaw.com

    https://www.gtlaw.com/en/insights/2016/7/gts-quick-guide-to-section-338h10-elections

    WEBJul 19, 2016 · 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.

    DA: 66 PA: 5 MOZ Rank: 94

  • Sec. 338. Certain Stock Purchases Treated As Asset Acquisitions

    bloombergtax.com

    https://irc.bloombergtax.com/public/uscode/doc/irc/section_338

    WEBI.R.C. § 338(h)(10) Elective Recognition Of Gain Or Loss By Target Corporation, Together With Nonrecognition Of Gain Or Loss On Stock Sold By Selling Consolidated Group

    DA: 18 PA: 4 MOZ Rank: 81

  • GT’s Quick Guide to Section 338(h)(10) Elections - gtlaw.com

    gtlaw.com

    https://www.gtlaw.com/-/media/files/insights/alerts/alerts-prior-to-march-27-2017/030107_gt-alert_338-election-quick-guide.pdf?sc_lang=en

    WEBMar 27, 2017 · 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.

    DA: 11 PA: 86 MOZ Rank: 82