Joy Marcus owns several income-producing assets, including a stock portfolio and a small services proprietorship. She wants to start a new corporation in the country Molto, where the income tax rates are about one-third of those in the United States, and transfer all of her assets and operations there.

How tax-effective is Joy’s plan in shifting the income from her activities when they are placed in the Molto corporation? Write a memo for the tax research file highlighting the Federal income tax rules that apply.