leveraged recapitalization 为什么不行呢

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：

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.