VMware was acquired by Broadcom. In this deal, a typical VMware shareholder:
- Had 47.9% of their shares converted to cash at $142.50 per share.
- Had 52.1% of their shares converted into 0.252 Broadcom shares.
After normalizing this, each VMware share yielded:
- a cash consideration of $68.25 (i.e., 47.9% * $142.50).
- a stock consideration of $128.60, representing 0.131292 Broadcom (AVGO) shares (52.1% * 0.252 shares). Based on Broadcom’s stock price of $979.50 on November 24, 2023, these 0.131292 AVGO shares would be worth $128.60.
In total, this amounts to $196.85 per VMware share, broken down as:
- 34.6% in cash consideration ($68.25),
- 65.4% in stock consideration ($128.60).
Now, for someone holding 100 VMware shares purchased at $150 per share (or $15,000 total cost basis), the question arises: How should the cost basis be allocated between the cash (realized in 2023) and stock considerations (possibly realized after 2023)?
Here are two potential approaches:
Proportional Allocation: Should the $15,000 original cost basis be allocated proportionally—34.6% to the cash received and 65.4% to the stock received? This would allocate $5,190 (34.6%) to the cash consideration and $9,810 (65.4%) to the stock consideration.
Stock-First Allocation: Alternatively, should the $15,000 cost basis first be applied to the stock consideration (i.e., 100 * $128.60 = $12,860), with the remaining $2,140 allocated to the cash consideration?
Which method of cost basis allocation is most appropriate in this case?