Final regulations on deemed asset sale elections offer taxpayers more flexibility

May 2013


The IRS on May 15 published final regulations under Section 336(e), which permits taxpayers to elect to treat certain dispositions of a target corporation’s stock as a sale of the underlying assets of the target corporation.  The final regulations provide more flexibility to taxpayers than the proposed regulations. The final regulations apply to any qualified stock disposition (QSD) for which the disposition date is on or after May 15, 2013.

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