WebIRC 338(h)(10) allows a buyer to purchase the assets of an S corporation in a taxable transaction and receive a step-up in basis for the assets acquired. This can affect the asset approach to valuation because it allows the buyer of the assets to depreciate the purchased assets over a shorter period of time, resulting in lower taxes. WebFeb 2, 2006 · Section 358 (d) (1) further provides that, in § 358 analysis, an assumption of liability by the transferee shall be treated as “money received” by the transferor. A transferor reduces its basis in the stock received from the transferee by the amount of any liability the transferee assumed in exchange.
BLACK DECKER CORPORATION v. UNITED STATES (2006) FindLaw
WebMay 22, 2024 · UILC: 351.11-00, 358.02-00, 1223.12-00 : May 22, 2024 : Scott A. Ballint Director, Enterprise Activities Practice Area (LB&I) : Robert H. Wellen ... Various provisions of the Internal Revenue Code (Code) provide favorable treatment when taxpayers dispose of capital assets with holding periods that exceed WebMay 4, 2004 · 1999, whether I. R. C. § 358(h) applies. ISSUE 3 Whether the contingent liability is a liability that gives rise to a deduction within the meaning of I. R. C. § 357(c)(3) … greenport cherry blossom festival 2022
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Web(b) Transfers by partnerships. If a corporation assumes a section 358(h) liability from a partnership in an exchange to which section 358(a) applies, then, for purposes of applying section 705 (determination of basis of partner's interest) and § 1.704-1(b), any reduction, under section 358(h)(1), in the partnership's basis in corporate stock received in the … WebJan 1, 2024 · Internal Revenue Code § 358. Basis to distributees. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the … greenport commons greenport ny