Question
K Corporation wants to acquire all the assets of the StiffChip division of P Corporation. These assets include intellectual property (brand names), and equipment held
K Corporation wants to acquire all the assets of the StiffChip division of P Corporation. These assets include intellectual property (brand names), and equipment held directly by P Corporation, as well as stock in StiffChip, Inc., a 100% owned subsidiary of P Corporation. Stiffchip, Inc.s assets have a value of $150m and a tax basis of $50m; P Corporations basis in the stock of StiffChip, Inc. is also $50m. K Corporation will pay P Corporation a lump sum of $200m in cash in return for both P Corporations StiffChip division assets and the stock of StiffChip, Inc.
Describe the federal tax consequences of this acquisition and the options or elections available to K Corporation to enhance its tax result from the acquisition.
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