U.S. Taxation of Foreign Investors
(General Overview)

  • 1.5 CLE Credits
  • Updated with Trump 2017 Tax Cut and Jobs Act
  • CLE CREDIT NOTE: The Florida Bar requires the full presentation is viewed and this survey is completed at the end of the presentation, before credits can be provided. Thank you.



  • Total presentation time: 90:00

A basic introduction to the tax laws of the United States as they apply to the foreign investor.

United States Taxation of Foreign Investors – Seminar Outline

  1. Taxation Pattern
  2. Status for Tax Purposes
  3. Two Types of Federal Income Taxation Patterns
  4. The Branch Profits Tax and Bilateral Treaties
  5. Exceptional Circumstances and Special Tax Benefits
  6. Real Estate – Taxation Pattern
  7. Ownership of Real Property
  8. Tax Planning Benefits and Traps Unique to the Foreign Investor in Real Estate
  9. The Tax Planning Structures

Topics discussed in this seminar include: Defining the foreign investor, taxation patterns, non-resident alien individuals, United States Status for tax purposes, understanding the substantial presence test, foreign students, investors subject to taxation, branch tax on corporations, two types of investor taxation, exceptions to the general rule, the effect of bilateral treaties, effectively connected income, source of income, estate and gift taxation, tax planning opportunities, investing in US real estate, practical real estate advise, taxation of United States real estate, real estate investments, available entities, real estate tax planning tools, portfolio loan, understanding the “like kind” exchange.

Presentation Resource Archives:

  1. Pre-Trump Presentation slides download as pdf
  2. A basic introduction to the tax laws of the United States as they apply to that foreign investor.
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