A U.S. citizen, owns 1% of USAco, a domestic corporation. All other shareholders of USAco are unrelated foreign persons. In a Type B reorganization, FORco transfers shares of its voting stock to USAco shareholders in exchange for 100% of the stock in USAco. The 1% owner U.S. citizen realizes a gain on the exchange. As a renowned and reputable international tax planning consultants, the 1% owner U.S. citizen retains your services so that he can minimize any potential tax liabilities.

Relying on the concepts learned from the assigned materials for this module, in a brief advising the 1% owner U.S. citizen you are required to:

How can the U.S. citizen avoid the outbound-toll charge on the gain?.