US Cross-Border Tax Blog

Published by W.L. Dueck LLP

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Catherine Shen-Weafer

Is the interest expense deductible for US non-resident aliens owning a US real property interest?

Loaning between business entities is a widely-adopted business strategy in the real estate industry. Multiple levels of entities are often chosen in a business structure. U.S. limited liability companies (“LLC”) are commonly used to hold U.S. real property interests. When foreign investors are involved for various reasons (i.e., asset protection), foreign investors use a non-U.S. corporation that is treated as a disregarded entity for U.S. federal income tax purposes to be the sole owner of the U.S. LLC. When the… Read More