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Non-US Investors Could Minimize FIRPTA with Smart Structuring

Tax Management International Journal
Bloomberg Tax

Article

10.29.26

Non-US investment continues to represent an important source of capital in the US real estate market, with year-to-date cross-border investment into the US reaching $14.4 billion as of the second quarter of 2026. CBRE Q2 2026 U.S. Capital Markets Report. Appropriate tax structuring is critical, as non-US investors are subject to complex federal income tax laws and regulations that can have a significant economic impact on investment returns. In this article, Kenneth Wang and Lauren Keller discuss a variety of structuring approaches.

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