Georgia (and New York) Reexamine their IRC Section 338(h)(10) Election for S Corporations, Jones Day State Tax ReturnJonesDay
However, the tenure of the CEO significantly increases the likelihood of permitting a Section 83(b) election. Research limitations/implications – This study is limited in the sense that it only examines the year 2004 and the results may be unique to that year. An extension of this study to...
Treatment of contingent liabilities after a sec. 338(g) election.(IRC section 338(g))Trachtenberg, Jane I
The article focuses on the decision of a Pennsylvania court regarding the Canteen Corporation versus Commonwealth that was filed on February 8, 2002. The court ruled that an election under Internal Revenue Code Section 338(h)(10) to treat the accompanying transfer of assets in a subsidiary ...