Discussion Post
338(a)(1) shall be treated as having sold all its assets at the close of the acquisition date at fair market value in a single transaction, and 338(a)(2) shall be treated as a new corporation which purchased all the assets referred to in paragraph one as of the beginning of the day after the acquisition date. IRC Section 338 allows a deemed sale election generating immediate taxation to the target corporation and a stepped-up or stepped-down basis to the price paid by the acquiring corporation for the target corporation stock plus liabilities on the deemed sale.
o Examine the benefits of IRC Section 338 liquidation election for a target corporation and create a scenario that would demonstrate a favorable Section 338 liquidation election for a target corporation.
The response must include a reference list. Using one-inch margins, double-space, Times New Roman 12 pnt font and APA style of writing and citations.