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How the deemed asset sale should be reported

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Green Leaf Corporation acquired the stock of Apple Corporation and made a valid Section 338 election in conjunction with the stock seller to treat the stock purchase as an asset purchase. Write a letter to Green Leaf Corporation in which you answer the following:

Question 1: How this choice is permissible under Section 338, including the specific subsection applicable to this scenario;

Question 2: How the deemed asset sale should be reported on the target company's consolidated income tax return; and

Question 3: Why Green Leaf Corporation would choose to treat the acquisition this way - what benefit do they stand to gain?

Reference no: EM132587486

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