NO.PZ2021090804000001
问题如下：
Johnson is a tax adviser who provides tax awareness advice to private clients. One of Johnson’s clients is Lily, who is an American citizen and lives in the United States.
Lily is the founder and sole owner of MTT, a private biopharmaceutical company based in the United States. In addition to owning MTT, Lily is the sole owner of the property that the company uses as its headquarters. The vast majority of Lily's wealth is represented by these two assets. Lily's tax cost basis in these two assets is close to zero.
Lily wants to reduce the risks associated with two centralized ownership positions. Lily's main goal is to reduce the concentration risk of two positions without triggering taxable events while maintaining exclusive ownership.
Johnson's risk mitigation strategy for Lily to achieve its main objective in terms of the position of MTT ownership is:
选项：
A. have MTT conduct a leveraged recapitalization.
B. establish a charitable remainder trust using MTT shares.
C. obtain a personal line of credit secured by MTT shares.
解释：
C is correct
Lily can obtain a personal loan secured by his private company shares in MTT to meet her primary objective of mitigating the concentration risk of both ownership positions without triggering a taxable event while maintaining sole ownership. One of the key benefits is that this type of borrowing should not cause an immediate taxable event.Lily would have access to cash to diversify his concentration risk while maintaining sole ownership of the company.
Lily 的目标是在diversified concentrated risk 上有两点要求，第一尽量不交税，第二保持对公司的控制权，而选项C就是拿MTT的的shares去抵押贷款，拿到的钱去构建分散化的组合，这个大目标首先实现了，然后呢由于没有交易（就是没有卖出shares）所以不会触发交税，然后property虽然抵押出去了，但实际所有者还是Lily，仍然控制着公司。
而A选项私募股权公司向高级和夹层贷方提供或安排债务。私有企业的所有者卖出其部分股份收取现金，并保留在新资本化实体中的少数股权。而所有者目前会面临对收到的现金征税。也就是这个虽然分散了风险，但是触发了交税，还丧失了控制权
B选项使用 MTT 股份建立慈善剩余信托将涉及 Lily 将他的股份捐赠给信托并获得gift的税收减免。虽然没有触发税务，然而，这将导致Lily放弃MTT 的独家所有权，这将违反他保持独家所有权的主要目标。
最后总结表格中说不会trigger tax和另外那个截图里的老股转让交税是不是矛盾了
