In the case of a U.S. acquisition of a foreign target, it was oftentimes beneficial to make a Section 338(g) election.
In general, the impact of a Sec. 338 election is that a stock acquisition is treated as an asset acquisition.
In the original Practice Aid, there was no mention of the back-solve approach. Since then the technique has come into widespread use.
How Do You Put a Price Tag on the Panama Canal?