Interest Deduction Limit under TCJA Under the Tax Cuts and Jobs Act of 2017 (TCJA), the deduction for interest paid or accrued to a related or unrelated party is limited to the sum of the taxpayer’s business interest income and 30% of adjusted taxable income for the year.   For taxable years before 2022, the limitation... Read More

The IRS has noted its awareness of the significant increase in inbound U.S. real property investment by foreign investors.  More recently, lower interest rates combined with a weaker U.S. dollar have continuously motivated inbound foreign investors to acquire U.S. real property.  The momentum of foreign investors is driven by the opportunity for appreciation in value... Read More

Foreign investors are often motivated to acquire U.S. real property when considering the opportunity for appreciation in value and a profitable return on investment.  There are different investment structuring alternatives that may attract foreign investors to the U.S. real estate market.  A common typical structure that has certain advantages is the U.S. blocker corporation.  The... Read More