Got a tricky question? Receive an answer from students like you! Try us!

Discussion of Sections 338 and 338 Election of the Internal Revenue Code - Research Proposal Example

Only on StudentShare
Undergraduate
Research Proposal
Law
Pages 10 (2510 words)

Summary

As part of the government’s aim to have tax equity and fiscal responsibility, Section 338 was enacted in 1982. A few amendments were then made but significant changes were made under Tax Reform Act in 1984. To reflect the changes made in Section 338, repealing the General Utilities Doctrine, the Congress made some changes in 1986…

Extract of sample
Discussion of Sections 338 and 338 Election of the Internal Revenue Code

Under Section 338, if a purchasing corporation acquires 80 percent or more of the stock of the target corporation in a qualified stock purchase then the election in Section 338 may be done to treat the stock purchase as an asset purchase. This election must be not later than the fifteenth day of the ninth month, after the month in which the acquisition date occurs. If however the purchasing corporation decides not to or fails to make such an election, then it will be a carryover basis in the target’s assets. Such an election in Section 338 will benefit or have an economic value to the purchasing corporation only “if the present value of future tax savings resulting from the ‘step-up’ in basis of the target's assets exceeds the current tax cost of such a step-up”. As explained by Silverman, in order to achieve this basis step-up, the target corporation must recognize the full gain or loss inherent in its assets. ...
Download paper
Not exactly what you need?

Related Essays

Joseph H Pilates
By the age of 14 he was the penultimate model, and had even begun modeling for anatomy charts.…
2 pages (502 words)
HRM Overview
The organizational function that deals with the people ." (Heathfield, 2007).…
16 pages (4016 words)
Personal Science Overview
Science has different meanings to it and is vast. Keeping it general and not making it very complex, the things we observe with our ears relates to science; science describes how sound waves strike your eardrum and then the process gets complex. Science describes it all, and if there are answers to our everyday questions, science stands the only capable subject to fulfill the blank answer spaces. A conceptual subject always helps on attaining success and going high as compared to other relatively easier subjects that seem to be nice for the short span of time but have limited advantages in the…
3 pages (753 words)
wk 10 (61)
This is an additional certification that an individual counselor can add to their state licensure requirement. Some people think that this is all they need to do for state certification but this is not the same as state licensure requirements although many may be similar.…
2 pages (502 words)
Discussion Question week 10
This site became approved after the US FDA audit at Jigani, which is another plant owned by Hikal Limited.…
1 pages (251 words)