Learn How Each Section 338 Election Functions in a Stock Sale
Can a buyer acquire a target corporation's stock for legal purposes but its assets for tax purposes, resulting in a stepped-up basis in the target corporation's assets? Fortunately, the answer is YES, when one of the two Section 338 elections is made, viz. 338(g) or 338(h)(10). Similarly, the Section 336(e) election can be advantageous for stock transfers to non-corporate purchasers. But how and when can you use the elections when the stock is being purchased or disposed?
Learn the mechanics of all three elections in this detailed webinar by taxation and accounting expert Vicki L. Mulak, EA, CFP®. She will walk you through all three elections, show you how these elections are made, and which elections are appropriate for which client scenario. Mulak will use practical scenarios in this webinar, and also provide a tax reform update affecting scenarios where target corporations are controlled foreign corporations (CFCs).
After attending this webinar, you will know how and when to use the elections when stock is being purchased or disposed. You will be able to calculate the basis in assets that result from the election for the purchaser, and calculate the gain to the seller. This webinar will also make you more confident in recognizing how “old target” and “new target” are treated for tax purposes with each of the three elections.
In this webinar, you will learn:
How each Section 338 election functions in a sale of stock
How to calculate the Aggregate Deemed Sale Price (ADSP) and the Adjusted Grossed-Up Basis (AGUB)
How to calculate the Aggregate Deemed Asset Disposition Price (ADADP) for 336(e) elections
How to properly complete IRS election Form 8023 and asset allocation Form 8883
Vicki L. Mulak is an Enrolled Agent and Certified Financial Planner (CFP) and owner of American Financial and Tax, a tax preparation, planning and representation firm, which was founded in Tustin, California in 1985, when Vicki became both a resident and a business owner.