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Upon the death of his grandfather, Mason inherited a 100% ownership interest in an LLC which owns and operates a major shopping mall in Salt
Upon the death of his grandfather, Mason inherited a 100% ownership interest in an LLC which owns and operates a major shopping mall in Salt Lake City, Utah. The shopping mall generates rental income each year as well as interest income from the short-term investment of excess working capital. Mason hates to pay income taxes, which is why he chose to become a permanent resident of the Cayman Islands shortly after finishing his college education. As you already know the Cayman Islands has no income tax. Mason remains a citizen of the United States. Upon learning of his grandfather's death, Mason instantly remembered a strategy he learned while in college known as an inversion. Mason formed a corporation in the Cayman Islands which he named TaxLess. Inc. Then Mason merged his U.S. LLC intem TaxLess. Inc. under a plan of merger which left TaxLess, Inc. as the surviving entity. a) (5 Points). Will the dividends received deduction be available as a tool to reduce any U.S. tax consequences to either Mason or TaxLess. Inc
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