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Attorneys Consider Tax Structuring of Foreign Investment in U.S. Real Estate

June 2, 2009

With U.S. real estate prices at historic lows, more properties have become attractive to foreign investors. Bryan Cave LLP New York Partner Jack Mandel and Counsel Alan Appel co-authored an article in the June edition of Institutional Investment Real Estate Magazin on the structures available to help limit the tax exposure on an investment in U.S. real estate by foreign investors.

Among other investment models, their article outlines ownership without interposing corporation; single-tier corporate ownership; and the foreign-U.S. corporation combination structure, which “is usually the structure of choice, with due consideration to multiple property issues,” they write.

Mandel’s primary areas of practice are partnership taxation, real estate-related tax matters, U.S. taxation of foreign investors and state and local taxation. He has served on various ad hoc bar association and real estate industry committees that have worked with officials of the New York State Department of Taxation and Finance on transfer and gains tax regulations. In addition, he has lectured and written about real estate-related tax matters.

Appel specializes in domestic and international tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, limited liability companies and tax controversy matters. A frequent author and speaker on tax matters, Appel is chair-elect of the U.S. Activities of Foreigners & Tax Treaties Committee of the ABA Section of Taxation.

Click on the attachment below to read their full article, reprinted with permission from Institutional Investment Real Estate Magazin at

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