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QUESTION

Taxation (2)

ABC Corporation acquired 20% of XYZ Corporation on January 2, April 1, June 1, October 1 and December 31 of the year 20x1.

  1. Has a qualified stock purchase taken place? How long does ABC Corporation have to make a Section 338 election?
  2. How would your response above change if the dates were January 2, April 1, and September 2 of 20x1 and January 4 and April 15, 20x2?
  3. If either part of question “a” or question “b” fails to be a qualified stock purchase, what is the latest date that ABC Corporation could make the final stock purchase to qualify for Section 338? (Assume that ABC Corporation made its initial purchase on April 1 of 20x1).

Requirements: Use the Template for Option 1 (linked at the bottom of the page) for the Critical Thinking Assignment for this week. Clearly identify the requirement being addressed. Show or explain all calculations within the body of the submission document. This means that you must use formulas and links so that your thought process can be examined. Make good use of comments to convey your thought process as well.

No hard coding of solutions. Review the Critical Thinking grading rubric, which may be found in the Module 2 folder, to see how you will be graded on this assignment.

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