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Paaeent Law Rules
b Debt financing
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12-month acquisition period acquired corporation's acquiring corporation acquisition date action carryover election adjusted basis affected target affirmative action carryover Answer apply asset acquisition buyer capital gain cash consolidated return debt deductions deemed election deemed sale depreciation distribution dividend election under section elective ADSP formula employer equity ESOP Example exchange express election fair market value filed gain or loss grossed-up basis group member ICA gain amount interest Internal Revenue Service issuer junk bonds leveraged buyout liquidation nonrecently purchased old T's ordinary income original issue discount P's basis paragraph partnership payment percent preferred stock protective carryover election purchased T stock pursuant qualified stock purchase recapture gain recently purchased redemption remaining ICA gain result reverse merger sale of assets section 338 election section 338(eXl shareholders shares step-up subsidiary T's assets target affiliate target corporation tax benefits tax liability taxable income tion transaction transfer treated treatment warrants