Foreign investors can own U.S. real estate using a variety of holding structures. There is no simple and obviously “best” choice. This session compares taxation of rental income and capital gain, as well as estate and gift tax exposure for a foreign investor. With the 2017 tax law changes, corporations are now much more interesting than they used to be.
Identify pros and cons for a variety of real estate holding structures
Recognize non-tax related issues for certain holding structures
Determine best holding structure based on company activities
* Estate tax planning and optimum real estate holding structures
* Capital gain tax planning and holding structure selection
* Taxation of rental income earned by foreign investors
* Branch profits tax, personal holding company tax, and accumulated earnings tax for corporate holding structures
Lawyers and CPAs.