Philip is the sole owner of Alto, a Canadian controlled private corporation that manufactures optical lenses. He decided to create a holding company, HOL DCO, to hold his shares in Alto. He bought 50% of the non-voting common shares of HOL DCO, while his wife Teresa bought 30% and each of their 4 children acquired 5% each. He then transferred his shares in Alto into HOLDCO in exchange for all of the preferred voting shares of the HOLDCO. All of the following statements are true, EXCEPT: Philip has affected a partial estate freeze. Philip has successfully arranged a way for Teresa to benefit financially from Alto's success without giving her any control over the management of the business. Any dividends paid by Alto to HOLDCO will be subject to a refundable Part IV tax. He can protect Alto's profits from the corporation's creditors by paying dividends into the HOLDCO