Final Regulations under Section 336(e)
Recently finalized regulations generally make available an election (under Section 336(e) of the Internal Revenue Code of 1986, as amended) to treat a transfer by a parent U.S. corporation of the stock of a subsidiary U.S. corporation (or the transfer by shareholders of the stock of an S corporation) as a sale of the assets of the sold corporation. This treatment generally enables a step-up in basis of the assets of the sold corporation (similar to the step-up available if an election is made under Section 338(h)(10)).