Section 336(e) Election & Liquidations for S and C corporations

Description

This class will explore the advantages and disadvantages of making a §336(e) election on the disposition of stock in an S corporation.

Highlights

LINK AND INSTRUCTIONS TO COME FROM AES TAX ONE DAY PRIOR TO SESSION

Objectives

After completing this course the participant will be able to:

• Define a §336(e) election and determine when it might be used by a purchaser of stock of an S corporation.
• Discuss the advantages and disadvantages of a §336(e) election.
• Explain the situations where a §336(e) election might be considered.
• Discuss the requirements to make a §336(e) election and to file Form 8883.
• Compare the §336(e) election to a §338(h)(10) election.
• Discuss the four steps that are considered to occur if a §336(e) election is made - sale, liquidation, formation and purchase, and filing Form 2553 - as well as tax returns that are required to be filed for the seller and the purchaser.
• Define a qualified stock disposition under §336(e) and compare it to a qualified stock purchase under §338(h)(10) and filing Form 8023.
• Determine the forms that need to be filed to make a §336(e) election.
• Describe the difference between the §336(e) election and the election under §338(h)(10).
• Describe the use of an F reorganization as a way to facilitate the sale of an interest in an S corporation using a QSub election and Form 8869.