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The overall tax effect to all parties of a QSD with a Sec.
The disposition date is the first day on which there is a QSD of T.
The sale of T's stock is a QSD. Old T is deemed to sell its assets to new T with an ADADP of $10,000, resulting in a $2,000 gain to old T.
338(h)(10) election could prove beneficial in negotiating and structuring a transaction that qualifies as a QSD. Furthermore, as the Sec.
The distribution of T's stock is a QSD. Old T is deemed to sell its assets to new T, which is treated as an unrelated person, at the close of the disposition date for the ADADP of $10,000, resulting in a $2,000 gain to old T.
Under the final regulations, if S has a distribution of T stock that is a QSD or part of a QSD and makes the election under Sec.
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