GiantSoft Corporation wants to acquire all the assets of the wireless handset division of Nukeme Corporation (a domestic corporation). These assets include:
1) Intellectual property (brand names) owned directly by Nukeme, - value $75m, no tax basis;
2) Equipment held directly by Nukeme (value $75m, tax basis of $50m, and
3) Corporate stock in Handset, Inc., a 100% owned domestic subsidiary directly owned by Nukeme (value $50m). Handset owns certain assets of its own (with a basis of $10m to it) and has no debt.
Nukeme Corporation's basis in the stock of Handset, Inc. is also $50m. GiantSoft Corporation will pay Nukeme Corporation a lump sum of $200m in cash in return for both: 1) Nukeme Corporation's handset division assets (IP and equipment), PLUS 2) the stock of its subsidiary, Handset, Inc. Describe the federal tax consequences of this acquisition and the options or elections available to GaintSoft Corporation to enhance its tax result from the acquisition. In particular, what amount of the lump sum purchase price should be allocated to the Handset, Inc., stock and the wireless handset division assets, respectively?