24. A HONG KONG BENEFICIARY (WITH NO CONNECTION TO THE U.S.) RECEIVES AN INCOME DISTRBITUION FROM AN IRREVOCABLE GIFT TRUST. THE BENEFICIARY'S UNCLE WHO IS ALSO A HONG KONG PERSON WITH NO CONNECTION TO THE U.S. HAS INVESTMENT AUTHORITY OVER THE TRUST'S ASSETS. THE TRUST WAS ESTABLISHED IN TENNESSE. a. IF THE INCOME DISTRIBUTION IS COMPRISED OF CAPITAL GAINS (FROM THE SELL OF U.S. COMPANY STOCK) AND DIVIDEND INCOME (FROM U.S. CORPORATE SHARE OWNERSHIP), WHAT IS THE APPLICABLE U.S. WITHHOLDING TAX RATE, IF ANY, ON THE DIVIDEND INCOME? b. WHAT IS THE APPLICABLE U.S. WITHHOLDING TAX RATE, IF ANY, ON THE CAPITAL GAIN INCOME? c. IS THERE A INCOME TAX TREATY WITH HONG KONG? d. WOULD THAT MATTER