If a domestic corporation transfers substantially all of its assets to a foreign corporation in an effort to possibly reduce such corporation's U.S. income tax liability, and such foreign corporation has substantially the same ownership that it previously had as a domestic corporation and such foreign corporation has no substantial business activities in the foreign country in which the foreign corporation is created or organized, such foreign corporation will continue to be taxed as a U.S. corporation for all U.S. tax purposes.

True

False