which a large publically traded U.S.
corporation ("US Corp"), with an Irish subsidiary ("ISub") which owns a substantial
amount of cash, may arrange for the transfer of that cash ... trust ("VI Trust") under the law
of the U.S. Virgin Islands ("USVI"). ISub would be the grantor of VI Trust and would
contribute cash to the trustee ("VI Trustee ... take the position that this distribution should not be recharacterized as a
dividend from ISub to US Corp.
ANALYSIS
There are several legal issues that have an impact