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...

I honestly don't know the answer to your question, though.

One could argue that Oracle's money is not technically his. This is how he gets a large share of Oracle's money into his own personal accounts without having to give other shareholders anything.

I'm calling it now. If this deal goes through Larry Ellison will buy a huge new boat.

Larry Ellison will buy a huge new boat regardless of this deal. It's just what he does.

Or purchase the other half of Malibu he doesn't own