Which of the Following Tax Benefits Does Not Arise When

Which of the following tax benefits does not arise when a U.S. corporation forms a corporation in Ireland through which to earn business profits in Ireland?

A) Flow-through of losses from the Irish corporation to the tax return of the U.S. corporation.
B) Potential deferral of U.S. tax on income earned by the corporation.
C) Treaty benefits on cross border payments between the Irish corporation and the U.S. corporation.
D) Use of transfer pricing to shift income between the United States and Ireland.