2. [20%] It's a year later (after your client in question 1 successfully acquired Target I) and you hear from her again. The CFO apprises you that the company wants to do another acquisition, but it also just received a huge payment in settlement of a patent infringement case it brought against Software Infringing Inc. In light of this cash windfall the CFO wants to pay cash for this next acquisition and she estimates the price to acquire Target II will =$100M. The CFO mentions that Target II is a U.S. C corporation wholly owned by ConsolidatedC@ also a U.S. based C corporation. Pursuant to IRC $15011505 ConsolidatedCo and Target II file a consolidated federal income tax return. Similar to the situation in question 2 , it is strongly preferred for business reasons that Target II survive as a legal entity, but the CFO also wants the most tax efficient transaction available because she is confident that her business (including the addition of Target II), will continue to be profitable for, at least, the next 15 years. The following are the assets of Target II: * Target II has various intangible assets (assembled workforce, intellectual property, trade name and trademarks, etc.). Also, in anticipation of the takeover, Target II has paid off all it debt and, consequently, has no liabilities. 2a.) Suggest a transaction that, again if the details can be worked out, should achieve your client's objectives. 2b.) If the deal closes achieving your client's objectives what would you expect the tax basis would be for the five assets listed above? Also, in future years (on a full year basis), what (approximately) tax deductions, if any, associated with the assets would you expect your client would be entitled to claim on its U.S. income tax returns? 2. [20%] It's a year later (after your client in question 1 successfully acquired Target I) and you hear from her again. The CFO apprises you that the company wants to do another acquisition, but it also just received a huge payment in settlement of a patent infringement case it brought against Software Infringing Inc. In light of this cash windfall the CFO wants to pay cash for this next acquisition and she estimates the price to acquire Target II will =$100M. The CFO mentions that Target II is a U.S. C corporation wholly owned by ConsolidatedC@ also a U.S. based C corporation. Pursuant to IRC $15011505 ConsolidatedCo and Target II file a consolidated federal income tax return. Similar to the situation in question 2 , it is strongly preferred for business reasons that Target II survive as a legal entity, but the CFO also wants the most tax efficient transaction available because she is confident that her business (including the addition of Target II), will continue to be profitable for, at least, the next 15 years. The following are the assets of Target II: * Target II has various intangible assets (assembled workforce, intellectual property, trade name and trademarks, etc.). Also, in anticipation of the takeover, Target II has paid off all it debt and, consequently, has no liabilities. 2a.) Suggest a transaction that, again if the details can be worked out, should achieve your client's objectives. 2b.) If the deal closes achieving your client's objectives what would you expect the tax basis would be for the five assets listed above? Also, in future years (on a full year basis), what (approximately) tax deductions, if any, associated with the assets would you expect your client would be entitled to claim on its U.S. income tax returns