Acquisitions are complicated in tax law. There was a good write-up about this in Forbes about a year ago that your question reminded me of: http://www.forbes.

Acquisitions are complicated in tax law. There was a good write-up about this in Forbes about a year ago that your question reminded me of: http://www.forbes.com/sites/anthonynitti/2015/10/05/tax-geek-tuesday-a-buyers-best-friend-understanding-the-section-338h10-election/ http://www.forbes.com/sites/anthonynitti/2015/10/05/tax-geek... I honestly don't know the answer to your question, though.