Law360, New York ( April 29, 2015, 11:06 AM EDT) -- The IRS and Treasury Department recently issued regulations that provide rules for making a "Section 336(e) election." This election is a relatively new tax planning tool to achieve a step-up in the tax basis of the target corporation's assets for income tax purposes where an asset purchase or a deemed asset purchase under Section 338 of the Internal Revenue Code is not available. A Section 336(e) election combines substantially similar tax consequences as a Section 338(h)(10) election (i.e., a step-up in the tax basis of the target corporation's assets) with a simpler transaction structure....
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