Intercorporate Dividends

If Mr. X owns 100% of Opco and Mr. X and his family members own Holdco. I just wanted to confirm that a tax-free intercorporate dividend is not possible from Opco to Holdco as Holdo does not own at least 10% of Opco. Please shed your thoughts.

My personal thought is that I get paid by clients to answer questions like these. And, while I don’t mind churning ideas around with other practitioners, I don’t like answering questions like these in public forums because they inevitably are either from non-pros looking for free “tax consulting” (what you pay is what it’s worth), or lack sufficient information to provide an informed answer. Given that there are three related questions here…I demur to answer.