#Look-Through Taxation
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Look-Through Taxation and the $1.8 Billion Wahaha Estate Dispute: From Dynastic Warfare to Regulatory Settlement
China’s look-through individual income tax rules for offshore trusts mandate a 20% tax across the full asset lifecycle, fundamentally restructuring the strategic game theory behind the $1.8 billion Wahaha estate battle. Legitimizing the trust now triggers dual Sino-US tax liabilities and an annual 18.25% late penalty, forcing dynastic litigation toward a tax-driven settlement.