Write an office memo discussing the federal tax consequences of the above transaction to both companies. Your analysis should consider all tax consequences including the amount and character of gains or losses recognized, the basis and character of assets acquired, and potential and actual future consequences. In addition, prepare forms 8594, Asset Acquisition Statement, for both companies with respect to this transaction.
The analysis and information you provide will be used by the parties accountants to prepare their respective tax returns for 2021 and subsequent years. You were not
provided any information about other tax issues of either client and were not asked for advice with respect to those issues. Therefore, you have no knowledge of either clients other transactions, gains or losses, carryovers, etc. Your advice should be framed as to this transaction only.
Please follow the Office Memo format, as outlined in the syllabus.
