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On Dec. 20, 2017, the House and Senate passed the Tax Cuts and Jobs Act, H.R.1, and this bill is on its way to President Trump for signature.  When signed into law, the Tax Cuts and Jobs Act would have a wide impact on various aspects of U.S. federal individual, corporate, partnership, international, and trust and estate taxation. This GT Alert provides a summary of certain key provisions of the Tax Cuts and Jobs Act as…
Section 338(h)(10) of the Internal Revenue Code can provide significant tax benefits to a buyer of 80% or more of a target corporation. A 338(h)(10) election allows a buyer of stock of an S corporation or a corporation within a consolidated group to treat the transaction as an acquisition of 100% of the assets of the target for tax purposes. The deemed asset sale for tax purposes increases the tax basis of the target’s assets…
Section 338(h)(10) of the Internal Revenue Code can provide significant tax benefits to a buyer of 80% or more of a target corporation.  A 338(h)(10) election allows a buyer of stock of an S corporation or a corporation within a consolidated group to treat the transaction as an acquisition of 100% of the assets of the target for tax purposes.  The deemed asset sale for tax purposes increases the tax basis of the target’s assets…
Introduction When reviewing U.S. stock option plans for our foreign clients, we are constantly asked to explain the difference in tax consequences between incentive stock option (ISO) plans and nonqualified stock option (NSO) plans. This is a frequently asked question as many U.S. companies offer their employees options to buy company stock at a specified price (commonly referred to as the option’s “strike price”). This post will provide a general summary of the tax consequences…