International Business

Foreign Investment in U.S. Real Estate

Jacob Stein

By  Jacob Stein Managing Partner, Aliant USA .

Foreign corporations that directly operate a business or own income-producing assets in the United States are subject to a 30% branch profits tax (BPT). For more foreign corporate investors in the U.S., this has led to structuring their U.S. investments through a U.S. corporate subsidiary, resulting in two layers of tax. This article will examine how a Chinese corporation can mitigate U.S. double taxation on their U.S. investments through the favorable application of an income tax treaty.

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