Since Mainland China advocated economic reform in 1978, the government appealed to many Taiwanese firms invested with a purpose of boosting trade and investing in this fast growing market. Some of the Taiwanese firms took this opportunity to expand and attain more profit and gradually developed into partners with major international enterprises in the supply chains. In order to increase the visibility in the world and increase the fundraising scale, numerous overseas Taiwanese firms chose to be listed in capital markets. A drastic change in government policy was seen in Taiwan since 2008. The regulations regarding foreign corporations listing in Taiwan capital markets have been largely loosened, which led to a sudden surge of appetite among successful overseas Taiwanese corporations for returning to Taiwan and be primary listed or secondary listed. This study is focused on overseas Taiwanese corporations based in Mainland China, where most of the primary listed firms operate and manufacture products. The main pragmatic issues discussed in this study include operating, managing, accounting and tax, and customs procedures¡Ketc. with a focus on illustration and analysis of tax related risks these firms encounter due to regulations in Mainland China when doing overseas investment restructuring, equity transfer and so on. This study not only investigate the issues of regulations for primary listing of securities in Taiwan, but also utilize case analysis to depict the development of primary listing oriented overseas investment structure and the frame of controlling of share holder¡¦s stock holding structures. Through practical experiences and diagrams to reveal the overseas operation and trading models in illustrations, the study has generated following verified summaries: 1. Analysis of regulations in China and the risk of taxes when corporations trying to make adjustment of overseas investment structure and transition of stock equity. 2. Study Taiwanese entrepurers or foreign companies, most of them are conglomerates companies or family owned business with centralized stock equity where they have the capability to highly conrol the core copany while they go public with the regard to the ownership and the level of controls in operation. 3. Utilize the formate of stock holding by overseas investment compay or through trust, to fullfill the consideration of equity diversification or reduce the burden of taxation.