Structuring Foreign Investment in US Real Estate Looseleaf

Foreign investors and their American counterparts generally share the goal of minimizing income tax liabilities from their US real estate investments. This rather straightforward aim is complicated by the fact that non-US investors must be concerned not only with income taxes in the United States, but in their home country as well. What's more, the United States has a special income tax regime that’s applicable to foreign persons. It’s quickly evident to those involved that this is a complex area subject to new developments as the US Congress continually entertains new tax laws (and other statutes with relevant impact like the PATRIOT Act), the Internal Revenue Service promulgates regulations, rulings, announcements and interpretations, and the US courts issue opinions impacting the area.

This timely and highly practical resource is designed to explore the considerations that are of unique concern to foreign individuals and entities making US real estate investments. To that end it details the US income, estate and gift tax aspects of inbound investment in US real property and the various structural techniques that may be employed to reduce or eliminate US tax liability under these domestic laws. This work's single-minded focus on real estate, the encyclopedic coverage of relevant tax considerations, and extensive materials on non-tax issues (asset protection, non-tax reporting, limits on foreign ownership of U.S, real estate, etc.) make it an essential resource for non-US investors and their advisers.