336(e) reorg

by a searcher from Charles Sturt University

2 months ago

Has anyone done 336(e) reorg and willing to share the procedural elements (how to execute)? My tax accountant is not familiar with it.

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6 comments

professional from Harvard University

If it’s just a simple situation where one person or a Husband-wife owned the S corp for its whole life you’re often fine with a 336e. If it’s more history than that…

2 months ago | like reply | 0 likes

professional from Walsh College of Accountancy and Business Administration

First, I'm assuming the target is an S-Corp or a member of a consolidated group. I avoid Section 336(e) and Section 338(h)(10) elections at all costs. The rules on eligibility can never be confirmed with certainty. Instead, I go the F-Reorg route and get the same tax implications to the buyer and seller. email me and we can talk about how I can help you execute this. --@----.com

2 months ago | like reply | 0 likes

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