Section 336(e)

News & Analysis as of

The 336(e) Election: Possible Deemed Asset Sale Treatment When a 338(h)(10) Election is Unavailable

For U.S. federal income tax purposes, a purchaser in a corporate acquisition typically prefers to acquire assets of a target corporation (“Target”) rather than stock because a purchaser that acquires assets is able to “step...more

New Regulations Provide Advantageous Acquisition Structures

New regulations issued by Treasury under Section 336(e) permit certain stock acquisitions to be treated as asset purchases, allowing buyers access to stepped-up asset basis and corresponding depreciation and amortization...more

New Section 336(e) Election Provides Additional Flexibility in Taxation of Stock Transactions

On May 15, 2013, the Department of the Treasury issued final regulations regarding a new election now permitted under Section 336(e) of the Internal Revenue Code that allows sellers to elect to treat transactions structured...more

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