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Question
1. Our clients do not want to incur a huge tax liability from this sale. Instead, they hope to structure a tax-deferred sale to avoid a large "tax hit." With that in mind, determine the tax consequences to CWC and its shareholders for each of the three transaction structures in parts a., b., and c. above that you researched individually.
2. What is your team's recommendation for the best transaction structure for this sale? Your choices are a fully-taxable transaction, one of the options in a., b., or c., above, or another structure. Justify your answer, discussing both tax and non-tax considerations that led to your conclusion.
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