USCo incorporated its foreign branch operations in Italy by transferring the branch's assets to a foreign corporation

Question:

USCo incorporated its foreign branch operations in Italy by transferring the branch's assets to a foreign corporation in return solely for stock in the new corporation. All of the branch's assets are located outside the United States and are used in the active conduct of a foreign trade or business. Is this transaction automatically eligible for tax deferral under § 351? Explain.

Corporation
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...