When considering how to structure a real estate investment in the United States, the foreign investor must be aware of the difference between a non-resident alien and an American taxpayer.

An American taxpayer is a U.S. citizen or an alien becoming a U.S. tax resident for purpose of income, gift and estate tax. The American taxpayer is taxed on his/her worldwide income (annually), on his/her assets (when they die) and gifts (during their life).