Examples of Section 336(e) Election in a sentence
Section 336(e) Election Section 1.179-4(c)(2) provides that property deemed to have been acquired by a new target corporation as a result of a section 338 election will be considered acquired by purchase for purposes of §1.179-4(c)(1).
It is intended that a Section 336(e) Election will have no effect unless the Distribution is a “qualified stock disposition,” as defined in Treasury Regulations Section 1.336(e)-1(b)(6), by reason of the application of Treasury RegulationsSection 1.336-1(b)(5)(i)(B) or Treasury Regulations Section 1.336-1(b)(5)(ii), or under any comparable provisions of state, local or non-U.S. law in any other jurisdiction.
One participant argued that making such support more dependent on responsibilities, whether at home or abroad, should not be seen as encroaching on other States’ sovereignty but as the home State acting more responsibly within an interconnected international system.
Potential partners include FRANZ Agreement allies (France, Australian and New Zealand), the United States Geological Survey (USGS), the National Oceanic and Atmospheric Administration (NOAA), and the US Navy and Air Force.
Section 336(e) Election Effective for certain sales, exchanges, or distributions of stock made by a domestic corporation on or after May 15, 2013, regulations under section 336(e) permit, in certain circumstances, a domestic corporation to elect to treat a sale, exchange, or distribution of the stock of a corporation as an asset sale.