Availability, mechanics, and consequences of section 336(e) [26 USCS § 336(e)] election., 26 CFR 1.336-2

Summary

Availability of election. A section 336(e) [26 USCS § 336(e)] election is available if seller or S corporation shareholder(s) dispose of stock of another corporation (target) in a qualified stock disposition (as defined in § 1.336-1(b)(6)). A section 336(e) [26 USCS § 336(e)] election is irrevocable. A section 336(e) [26 USCS § 336(e)] election is not available for transactions described in section 336(e) [26 USCS § 336(e)] that do not constitute qualified stock dispositions.

Deemed transaction —

Dispositions not described in section 355(d)(2) or (e)(2) [26 USCS § 355(d)(2) or (e)(2)] —

Old target — deemed asset disposition —

In general. This paragraph (b)(1) provides the Federal income tax consequences of a section 336(e) [26 USCS § 336(e)] election made with respect to a qualified stock disposition not described, in whole or in part, in section 355(d)(2) or (e)(2) [26 USCS § 355(d)(2) or (e)(2)]. For the Federal income tax consequences of a section 336(e) [26 USCS § ...