Conversion is treated as a taxable event. If you claim the IP is worth $0 but sell it two days later for $10M, you're going to have problems.
I think you missed my point, which was that if I own a corporation and it buys an asset, then I sell that corporation, are these things tied together?
If the corporation simply found a deal, then the owners of the corporation chose to sell, why would the corporation (or owners) get hit with a gain on asset (purchased by corporation) tax? The shareholders should be taxed as normal gain on assets (shares) and it should not be reflected in the taxes paid by the corporation, unless I am missing something.
Edit: I mean from inception/company formation. Wouldn't that save you all the aforementioned headaches? Especially when the time comes for an exit to happen.