Leveraging Final Sect. 336(e) Regulation Benefits in Acquisitions and Corporate Spin-Offs
Recording of a 110-minute CPE webinar with Q&A
This teleconference will provide tax professionals with a thorough briefing on using and realizing the potential benefits from the finalized Sect. 336(e) in instances of deemed asset sales.
Outline
- Sect. 336(e) finalized
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Who can use Sect. 336(e)
- Requirements for using Sect. 336(e)
- Special considerations that apply to S corporation targets
- Consequences of the Sect. 336(e) election
- Time and manner of making the Sect. 336(e) election
Benefits
The panel will explore topics such as:
- Deciding when a Sect. 336(e) election is preferable to a Sect. 338 election.
- Determining the availability of Sect. 336(e) election in certain spin-off transactions under Sect. 355.
- Meeting the requirements for making a Sect 336(e) election.
- Understanding the crucial aspects of the two models for a deemed asset sale under the regulations.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty
Leigh Griffith
Partner
Waller Lansden Dortch & Davis
He manages the firm's Tax Practice and has extensive experience in federal tax compliance and planning. He has... | Read More
He manages the firm's Tax Practice and has extensive experience in federal tax compliance and planning. He has written and spoken extensively on tax topics.
ClosePamela Glazier
Atty
Ropes & Gray
Her practice focuses on tax issues in private equity and M&A transactions. She also advises clients on tax matters... | Read More
Her practice focuses on tax issues in private equity and M&A transactions. She also advises clients on tax matters relating to investment companies.
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