IRS PLR: Rulings on Corporate Group’s Target Stock Distributions, Sale of Distributors (IRC §336)

A corporate group’s proposed distributions of acquired stock of two target companies among subsidiaries: (1) constitute Treasury Regulations Section 1.336-1(b)(6) qualified stock dispositions with respect to which tax code Section 336(e) elections may be made without recognition of gain or loss, and with such elections (2) the subsequent deemed sales of Target’s property through sales of their indirectly owning subsidiaries to an unrelated buyer will not be treated as transfers of franchises, trademarks, and trade names (Section 1253(a)) and (3) the anti-churning rules of Section 197(f)(9) will apply to any goodwill, going concern value, ...