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Section 338 consistency rules

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 https://flowingrivermartialart.com

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

26 CFR § 1.338-8 - Asset and stock consistency.

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Section 338 consistency rules

Avoiding the Section 338 Consistency Rules - Alston & Bird Tax Blog

WebReport recommends repeal of the consistency rules contained in sections 338(e) and (f) of the internal Revenue Code. We believe that, for a number of reasons, the consistency … Web1 Nov 1992 · The asset consistency rules of section 338(e) provided that, with certain exceptions, a purchase of assets from the target or a related corporation by the buyer of the target's stock was treated as subject to a constructive section 338 election with respect to the target. 1982 Conference Report at 536-37.

Section 338 consistency rules

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Web§ 1.338-3 Qualification for the section 338 election. (a) Scope. (b) Rules relating to qualified stock purchases. (1) Purchasing corporation requirement. (2) Purchase. (3) Acquisitions … Web25 Aug 2024 · that, in connection with an election under section 338(g), a section 245A shareholder of the new target generally does not succeed to an extraordinary disposition account with respect to the old target. However, the final regulations also contain special rules for transactions in which a section 338(g)

Web3 Mar 2004 · Section 338 (b) (5) states that the deemed purchase price "shall be allocated among the assets of the target corporation under regulations prescribed by the Secretary." … Web9 Apr 2012 · If Buyer had bought the stock of Seller 2, and affiliates owned by its shareholders had bought the assets, the consistency rule of section 338 might have been …

WebSection 125 Cafeteria Plan Rules for AdministeringMid‐Year EmployeeElectionChangeRequests According to IRS guidelines (Treas. Reg. §1.125‐4), participants can change their employee benefits elections under a Cafeteria Plan either (1) during an open enrollment Web23 Jan 1997 · This document contains final regulations relating to the consistency rules under section 338 of the Internal Revenue Code of 1986 that are applicable to certain cases involving controlled foreign corporations. The final regulations substantially revise and simplify the stock and asset consistency...

Webpurpose of the section is to extend the principles of section 338(h)(10) to transfers of stock not involving a qualified stock purchase or consolidated groups. The report recommends that section 336(e) (and a companion rule in section 338(h)(10)(B)) be implemented to the maximum permissible extent, subject to certain limitations in the case of

Web338 4 Asse t and stock consistenc y. T. D. 8710 DEPARTMENT OF THE TREASURY 26 CFR Part 1 Revisions of the Section 338 Consistency Rules With Respect to Target Affiliates … brain health breakthroughsWeb8 Jun 2007 · When Congress adopted Section 338 in 1982, it included two sets of consistency rules to prevent the continued availability of a means of extending the scope … brain healthcare quotientWebthe “338 Approach,” has historically resulted in significant increases to the Section 382 Limitation for many loss corporations and has ameliorated the impact of Section 382 even when the loss corporation does not actually dispose of built-in gain assets. Specifically, the 338 Approach allows corporations to determine items of RBIG or brain health care