I am not sure the law for LLC or LLP in China. Can you form a LLC or LLP in China?. But you surely can form it in other countries. In that case, the income of the company will pass to the shareholder and you pay US tax no mater if it is CFC or not. CFC rule is for Inc. or Corporation not for S, LLC and LLP. S, LLC, LLP is tax nuetral anyway. Did I answer your question?