Sam, a US tax resident individual wholly owns Hong Kong Ltd (treated as a corporation for US tax purposes) and it anticipates distributing a dividend in the upcoming tax year. Hong Kong imposed a 16% corporate tax rate and Hong Kong Ltd does not have any Subpart F income (including no GILTI income). If Sam imposes a US HoldCo (an Inc.) between himself and Hong Kong Ltd and Hong Kong Ltd distributes the dividend to US HoldCo (who then distributes such dividend to Sam), would the effective tax rate increase, decrease or remain the same compared to the current structure? Explain your reasoning and provide a calculation with effective tax rates.