Estimated taxes for Sec. 338(h) (10) transactions.
Author | Simpson, Kirsten |
Sec. 338(h)(13) generally provides that, for Sec. 6655 purposes--relating to payment of estimated taxes--the tax attributable to the sale described in Sec. 338(a)(1) (i.e., the asset sale deemed to occur as a result of a Sec. 338 election (including a Sec. 338(h)(10) election)) is not taken into account. Thus, Federal income taxes accruing from the deemed sale of appreciated assets by the "old" target corporation are not taken into account in the quarterly estimated tax calculus.
New Law
AJCA Section 839 amends Sec. 338(h)(13) to provide that it "shall not apply to a qualified stock purchase for which an election is made under [Section 338(h)(10)]."
Effective Date
This amendment applies to...
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