Taxable acquisition

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Taxable acquisition

A merger or consolidation that is not a acquisition. The selling shareholders are treated as having sold their shares.

Taxable Acquisition

A merger where the value of the assets a stockholder receives at the end of the transaction is substantially different from the value of assets before the transaction began. For tax purposes, stockholders are treated as having sold their shares, and are therefore subject to capital gains taxes.
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corporate tax system and the rules guiding corporate formation, capital structure, operating distributions, stock redemptions, stock dividends, complete liquidation, and taxable acquisitions.
In the context of taxable acquisitions, category 6 transaction costs are:
Example 11: A acquires TG in a taxable acquisition wherein A purchases all of TG's assets for $8 million.
With the changes coming about with TRA 86, practitioners may have concluded that taxable acquisitions are a dying breed.
Among other things, taxable acquisitions require careful tax planning concerning: 1) the allocation of purchase price; 2) the inheritance of the target's tax attributes; 3) the deductibility of acquisition expenses; and 4) miscellaneous tax provisions.
The annual conference draws tax specialists to participate in timely discussions of new developments and trends affecting the tax treatment of various types of merger and acquisition transactions, including taxable acquisitions, tax-free reorganizations, acquisitions involving firms filing consolidated returns, special tax issues arising in the negotiation of a merger or other acquisition agreement, state tax planning for acquisitions, and the tax consequences arising in cross border acquisitions.
In the context of taxable acquisitions, category 6 transaction costs are added to the basis of (1) assets if acquired, under Regs.
Example 13--category 6 transaction costs: The facts are the same as in Example 12, except that G acquired H in a taxable acquisition, purchasing all of H's assets for $8 million.
As previously stated, Chapters 2 and 3 address Buyer and Seller considerations in taxable acquisitions of foreign businesses by a U.
Taxable acquisitions generally require the recognition of gain or loss by the seller in the year of sale.
These recent TAMs confirm that the IRS will continue to allow a current deduction for acquisition-related severance as well, except for taxable acquisitions which present issues beyond the scope of INDOPCO.
263(a)-5 reserves on the treatment of capitalized costs incurred by a target corporation in a taxable acquisition of the target's stock where no section 338 election is made.