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A Survey Of The Section 336(E) Regulations, Don Leatherman
A Survey Of The Section 336(E) Regulations, Don Leatherman
College of Law Faculty Scholarship
Under § 336(e), if one corporation owns an affiliated interest in the stock of a second corporation and sells, exchanges, or distributes all of that stock, Congress has authorized a regulatory election to treat the transfer of the second corporation’s stock as a disposition of its assets, thereby avoiding recognized gain or loss on the sale, exchange, or distribution of that stock. Congress added § 336(e) to the Code in the Tax Reform Act of 1986, intending that it be implemented using "principles similar to those of section 338(h)(10)." Thus, § 336(e) has a purpose similar to § 338(h)(10), offering …
A Survey Of The Section 336(E) Regulations, Don Leatherman
A Survey Of The Section 336(E) Regulations, Don Leatherman
Scholarly Works
Under § 336(e), if one corporation owns an affiliated interest in the stock of a second corporation and sells, exchanges, or distributes all of that stock, Congress has authorized a regulatory election to treat the transfer of the second corporation’s stock as a disposition of its assets, thereby avoiding recognized gain or loss on the sale, exchange, or distribution of that stock. Congress added § 336(e) to the Code in the Tax Reform Act of 1986, intending that it be implemented using "principles similar to those of section 338(h)(10)." Thus, § 336(e) has a purpose similar to § 338(h)(10), offering …