Web20 Jan 1994 · Revision of Section 338 Consistency Rules. An Uncategorized Document by the Treasury Department on 01/20/1994. Document Details. Publication Date: 01/20/1994. Agency: Department of the Treasury. Dates: These … WebSection 1.338-7 addresses allocation of ADSP or AGUB when those amounts subsequently change. Asset and stock consistency are addressed in § 1.338-8. International aspects of section 338 are covered in § 1.338-9. Rules for the filing of returns are provided in § 1.338-10. Section 1.338-11 provides special rules for insurance company targets.
Definition: Consistency rules. from 26 CFR § 1.336-1 LII / Legal ...
WebThe deemed sale of assets pursuant to a section 338 election is treated as assumption reinsurance for tax purposes, but special rules are provided under section 338 that differ in some respects from the existing assumption reinsurance regulations at Treas. Reg. section 1.817-4(d). See Treas. Reg. section 1.338-1(a)(2). WebFor the purposes of the consistency rules, section 338 adopts the consolidated return definition of affiliated group without the exclusions, such as those for certain insurance … hacks sports bar
CEI 2024 Section 125 Permitted Election Change Event Chart
Web6 Jul 2024 · Linked below is a detailed report on the section 382 rules, that provide limitations on the use of tax attributes (carryforwards and built-in items) by corporations. ... Notice 2003-65 allowed taxpayers to choose from two different alternative approaches: section 338 and section 1374 approaches. The section 338 approach, generally more ... Web13 Dec 2024 · A Section 338(h)(10) election is much more common than a Section 338(g) election because the 338(g) election results in two levels of tax, whereas a 338(h)(10) election results in only one. In a regular Section 338 election, two levels of tax are imposed: one on the shareholders upon their sale of the target stock and the other on the deemed … Web5 Feb 2004 · In general, section 338 operates as follows: a. Purchase and election. (1) In one or more transactions occurring within a 12-month period (the "acquisition period"), the … brain health breakthrough