Smile Corporation invests $2 million for a 49% interest in Irehoe, Inc., a newly formed Irish corporation that manufactures farm equipment. Jim, a U.S. resident, owns 10% of Irehoe. Jim owns no stock in Smile Corporation. An Irish corporation owns the remaining Irehoe shares. Irehoe reports a profit for the current year of $150,000 and pays no dividends. Irehoe pays no income tax in Ireland because of a tax holiday for newly formed corporations with significant foreign ownership. Discuss the tax implications for Smile, Irehoe, and Jim.