I can answer only your U.S. immigration question, not really the tax question. The only visa that I see as a possibility is the L-1A
visa since he does not want a green card. For the L-1A visa, it seems you have more than enough of investment and that he owns a company outside of the U.S. for more than one year will work. That company outside must continue to run and produce. He cannot let it die. So I think with that, he is an excellent candidate for the L-1A visa. Here is an official link:
With such a large investment, I would hire an attorney to make sure that everything is done correctly because the money must be invested and at risk before they will approve the visa. You can look for an attorney at www.ailalawyer.com.
As far as the tax question, I can answer that to be considered a "resident" for tax purposes (and you do not need a green card for this), it is 180 days or more of time spent in the U.S. Also, keep in mind that the investment visa is not only to invest money in the U.S. and create jobs in the U.S., but also to pay taxes in the U.S. As far as how else he can avoid paying taxes, that I cannot answer for you, BUT if a treaty exists between the U.S. and China in regards XXXXX XXXXX (and I am not sure if one does), then he would be able to avoid having to pay double taxes on this investment and income.
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