Perk Labs Inc (PKLBF)

[Fiesta11]

Here LAO since i cant respond to you pm's you keep sending me!

LAO: EHHHHHHHHH?????????


The 1986 Tax Reform Act added a provision that allows a corporation (or all of the stockholders of an S Corporation) selling stock in a subsidiary to treat that sale as a “deemed sale” of assets. In 2013 the IRS issued its final regulations implementing the deemed sales provisions [Internal Revenue Code Sections 336(e) and 338(h)(10)]. Application of both sections of the Code requires the parties’ agreement to deemed sale treatment. A deemed sale of stock has the following benefits to both parties:

To the Buyer:

1. The seller treats the transaction as a capital transaction because stock is being sold.

2. Since stock is a non-depreciable asset, there is no recapture of depreciation of the assets being transferred.

3. As a sale of stock, the seller is able to jettison all of the liabilities that go with the corporation being sold.

4. Avoidance of state sales taxes on value of the assets transferred (though some states may tax the stock transfer)