Matthew Richardson

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Final Section 336(e) Regulations Allow Step-Up in Asset Tax Basis in Certain Stock Acquisitions

Final regulations were issued last month under IRC Section 336(e). These regulations present beneficial planning opportunities in certain circumstances. For qualifying transactions occurring on or after May 15, 2013, Section 336(e) allows certain taxpayers to elect to treat the sale, exchange or distribution of corporate stock as an asset sale, much like a Section 338(h)(10) … Continue Reading

California State Senate Passes Measure Providing Partial Relief From Cutler Decision (re: QSBS)

The California State Senate yesterday approved a measure providing relief (albeit only partial relief) to those taxpayers facing retroactive tax assessments by reason of the Cutler decision. In Cutler v. Franchise Tax Board the California Court of Appeal held that the California tax incentives relating to the sale of qualified small business stock discriminated against … Continue Reading
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