Question
On April 23, 2020, Auk Corporation acquires 100% of the outstanding stock of Amazon Corporation (E & P of $750,000) for $1.2 million. Amazon has
On April 23, 2020, Auk Corporation acquires 100% of the outstanding stock of Amazon Corporation (E & P of $750,000) for $1.2 million. Amazon has assets with a fair market value of $1.4 million (basis of $800,000), no liabilities, and no loss or tax credit carryovers. Amazon Corporation's tax rate is 34%. Auk Corporation files a timely 338 election. Assume that both the aggregate deemed sale price (ADSP) and adjusted grossed-up basis (AGUB) are $1,306,329. a. What are the tax consequences of the 338 election to Amazon Corporation and to Auk Corporation? b. Assume that Amazon Corporation is liquidated immediately following the 338 election. What are the tax consequences of the liquidation to Amazon Corporation and to Auk Corporation?
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