IRS Allows Sec. 338(h)(10) Election Made During Spinoff of Selling Corporation

In Letter Ruling 201220020 the IRS integrated an internal stock sale followed by a spinoff and ruled that the internal stock sale was eligible for a Sec. 338(h)(10) election.

Source: http://feedproxy.google.com/~r/AICPA_TaxAdvisor/~3/nL8JPUbScko/clinic-story-02.aspx

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