This was a Section 357 merger. If it had been a merger between two US-domiciled corporations it would probably have been tax-free with carryover basis. Because it was a merger of a US-domiciled company into a foreign company, it is a taxable transaction where the taxpayer must recognize gain but not loss. It is not the same result as a straight cash sale for $163.45 because in a straight cash sale you would recognize loss if there was one. Just use the stock merger calculator and you will arrive at the correct result.
