TAX 9866 Lecture Notes - Lecture 17: Intangible Asset

21 views3 pages
20 Dec 2019
Department
Course
Professor

Document Summary

Irc 338: qualified stock purchase: any transaction or series of transactions in which target stock meeting at least 80% of vote and value affiliation requirements is acquired by purchasing corp during 12 month period. P purchases 10 t shares on jan 1 of year 1. Another 10 t shares on march 1 of year 1, and 75 shares on feb 1 of year 2. A qualified stock purchase occurs on feb 1 of year 2. T"s 12 month period began march 1 of year 1. An llc that elects to be treated as corporation is also valid. Purge of all tax attributes [t"s tax attributes such as nol and e&p are lost after 338 election] T may offset any gain on deemed sale with nols held by t but may not use any nol from p. 338g: p, purchaser pays the tax, because after election p is in control of t. thus, if there are nols in the.

Get access

Grade+20% off
$8 USD/m$10 USD/m
Billed $96 USD annually
Grade+
Homework Help
Study Guides
Textbook Solutions
Class Notes
Textbook Notes
Booster Class
40 Verified Answers
Class+
$8 USD/m
Billed $96 USD annually
Class+
Homework Help
Study Guides
Textbook Solutions
Class Notes
Textbook Notes
Booster Class
30 Verified Answers

Related Documents

Related Questions