A Tax Sandwich – Not Tasty At All
When a foreign investor becomes a U.S. tax resident, one easily overlooked U.S. tax issue is that such residence change may result in an adverse U.S. tax structure, sometimes referred to as a “Sandwich Structure.” What is a Sandwich Structure? Let’s use an example to explain what a Sandwich Structure is. A Chinese tax resident, Mr. Wang, owns a manufacturing compa [...]