1. You moved to the United States in 2017 and became a US citizen in early 2019. You have two adult children. Your son is a citizen and resident of Japan. Your daughter is a citizen and resident of Canada. Both children are in need of immediate cash. You own 100% of the stock and serve as President of a very profitable family business which operates as a C-corp. In order to put immediate cash in your childrens hands you decide to transfer a 10% ownership interest in the family business to each of your children and declare a substantial dividend. At the same time, you require both children to sign an agreement that they will make a gift of their 10% ownership interest back to you at a time to be selected independently by each child, as long as the gift to you is completed by no later than December 31, 2025. Would you expect the Internal Revenue Service to challenge the validity of the original gift from you to the children? Name and describe as many as possible of the tools (or weapons) you think the IRS might use to challenge the validity of the gifts to your children?