ANSWER:
Long term U.S. real estate investment should be made through a foreign corporation in a selected country, which foreign corporation owns a U.S. corporation, which US corporation owns U.S. real estate. This structure minimizes income taxes and legitimately avoids all U.S. estate taxes; at the owner's death assets then pass tax free to his heirs.
The NRA owns stock in a foreign corporation. That is not a US asset. Even if the foreign corporation directly owns US real estate, no death taxes are imposed since the NRA owns no US asset. However, to avoid the Branch Profits Tax, a foreign corporation should not own US real estate. Therefore, the NRA owns foreign corporate stock; the foreign corporation owns a US corporation; freedom from US death taxes is achieved.
For more information, see NRA
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