A non-U.S. corporate entity investor held a real estate asset (a parcel of land) that that was purchased for $100,000,000 for 10 years and will sell it for $130,000,000. The investor gain on the sale of the asset is considered to in a business that is effectively connected to a U.S. trade or business (ECI).

1. Compute the tax on the sale assuming that the investor held the asset directly

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2. Compute the tax to the investor if held through a corporation (consider both entity tax and tax on the distributions) with no treaty rates and a plan of liquidation in the year of sale

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3. Describe a way in which the tax in item b) could be potentially lower