Consider a wealthy U.S. citizen who earns $1.3 million per year in dividends and capital gains from her portfolio of U.S. stocks. Can she legally avoid having this income subject to U.S. tax by...

Consider a wealthy U.S. citizen who earns $1.3 million per year in dividends and capital gains from her portfolio of U.S. stocks. Can she legally avoid having this income subject to U.S. tax by forming an offshore holding company and having the holding company own the stock? She has her holding company reinvest the dividends and capital gains, so she personally receives no cash from her investments.