Planning techniques


A number of planning techniques are available to foreign investors in U.S. real property that provide both income tax efficiency and estate and gift tax inapplicability.
That is, certain structures may be used to provide capital gain treatment of gains from the sale of U.S. real property interest and no estate tax inclusion of it in the foreigner’s estate.
Although a seemingly contradictory feat, the following techniques (and combinations and modifications thereof), each with its own benefits and drawbacks depending on the facts and circumstances, offer the best results.