From ownership structures and financing to tax planning and market selection — a complete guide for global buyers investing in U.S. luxury property.
By Anthony Guerriero — Manhattan Miami Real Estate
The United States remains one of the most accessible and well-protected real estate markets in the world for international buyers. There are no restrictions on foreign ownership, no punitive buyer taxes, and no caps on investment. The legal framework is transparent, property rights are strong, and transaction data is publicly available.
This guide covers the full scope of what international buyers need to understand before purchasing luxury real estate in the United States — from the strategic reasons global investors choose the U.S. market to the practical details of ownership structures, financing, taxation, and closing. It draws on more than two decades of experience advising international clients at Manhattan Miami Real Estate, with a focus on the two markets where we operate: New York City and Miami.
Global capital flows to the United States for a combination of reasons that few other countries can match simultaneously:
For a detailed comparison of how the U.S. treats foreign buyers relative to other major economies, read our guide: Can Foreigners Buy Property in the USA?
While foreign nationals purchase real estate across the United States, two markets consistently dominate international luxury transactions: New York City and Miami.
Manhattan is the world's most recognized luxury real estate market. International buyers are drawn to its global prestige, cultural richness, and long-term value stability. The island's supply constraints — 23 square miles with limited new construction — create a natural scarcity that underpins pricing. Manhattan's luxury condominium market offers foreign buyers transparent ownership, strong resale liquidity, and access to some of the world's most coveted addresses, including Billionaires' Row.
For a detailed market guide, read our International Buyers Guide to New York City Real Estate.
Miami has emerged as a global real estate capital in its own right, attracting buyers from Latin America, Europe, and the Middle East. Florida's lack of state income tax, combined with a thriving pre-construction market and an expanding inventory of branded residences, makes Miami one of the most financially attractive luxury markets in the world.
For a detailed market guide, read our International Buyers Guide to Miami Real Estate.
Many international buyers evaluate both markets before committing — and some ultimately purchase in both. For a side-by-side comparison of taxes, investment profiles, rental flexibility, and lifestyle, read our dedicated guide: NYC vs Miami Real Estate for International Buyers.
How you hold title to a U.S. property has significant implications for tax liability, estate planning, and liability protection. International buyers typically choose one of the following structures:
The simplest approach. You purchase the property in your personal name. This is straightforward and common for buyers who plan to use the property as a personal residence. However, direct ownership exposes you to U.S. estate tax on assets above $60,000 — a far lower threshold than the $13+ million exemption available to U.S. citizens.
The most common structure for international investors. Purchasing through a single-member LLC provides liability protection and simplifies tax reporting. When properly structured, an LLC can also be used as part of a broader estate planning strategy to reduce or eliminate estate tax exposure.
Some international buyers hold U.S. real estate through a foreign corporation. This structure can eliminate U.S. estate tax exposure entirely, but it introduces other considerations — including the Branch Profits Tax and more complex filing requirements. Professional guidance is essential.
Foreign trusts and domestic trusts are used by some buyers for estate planning purposes. The tax treatment varies significantly depending on the type of trust, the grantor's residency, and the terms of the trust instrument.
Important: Entity structuring for international real estate purchases is a specialized area of law and tax. We strongly recommend engaging a U.S. tax attorney and CPA with experience in international transactions before finalizing your ownership structure.
While a significant portion of international luxury purchases are made in cash, mortgage financing is available to qualified foreign nationals. Several U.S. lenders specialize in foreign national loans, and some international banks with U.S. operations offer cross-border lending programs.
Typical terms for foreign national mortgages include:
If you maintain an existing banking relationship with a global institution — such as HSBC, Citibank, or Santander — that relationship may provide access to preferential lending terms or cross-collateralization options.
This distinction is primarily relevant to the New York City market, where co-operatives represent roughly 70% of the residential housing stock.
Condominiums are real property. You receive a deed, and your ownership is recorded publicly. Most condo buildings allow rentals and resales with minimal board interference. For international buyers, condos provide the most transparent and flexible ownership experience.
Co-operatives are not real property — you purchase shares in a corporation that owns the building. Co-op boards have broad authority to approve or reject buyers, and the approval process typically includes extensive financial disclosure and a personal interview. Many co-ops restrict or prohibit subletting and impose financing limitations.
Our recommendation: International buyers should focus on condominiums. The co-op purchase process presents unnecessary complexity and risk for foreign nationals, and the restrictions on renting and resale significantly limit flexibility and liquidity.
In Miami, virtually all residential properties are condominiums, so this distinction does not apply.
New development condominiums are particularly popular with international buyers in both New York and Miami. In most new developments, the purchase is made directly from the developer — which eliminates the board approval process entirely.
Advantages of new development purchases include:
Browse current opportunities: New Development Condos in Manhattan | Miami Pre-Construction
Taxation is one of the most important — and most complex — aspects of international real estate investment in the United States. The following is a high-level overview. All international buyers should engage qualified U.S. tax counsel before purchasing.
Foreign nationals who earn rental income from U.S. real property are subject to federal income tax. If you elect to treat the income as "effectively connected" with a U.S. trade or business (which most investors do), you file a U.S. tax return and pay tax on net income after deductions — the same treatment available to U.S. taxpayers.
State-level taxation varies significantly. New York imposes state income tax (up to 10.9%) and New York City income tax (up to 3.876%) on income earned within the state. Florida, by contrast, has no state income tax — one of the primary reasons Miami has become so attractive to international investors.
When a foreign seller disposes of U.S. real property, the buyer is required to withhold 15% of the gross sale price and remit it to the IRS. This withholding functions as a prepayment of the seller's capital gains tax liability. Any overpayment is refundable when the seller files a U.S. tax return.
Foreign nationals who hold U.S. real property directly at the time of death may be subject to U.S. estate tax on assets exceeding $60,000. The estate tax rate can reach 40%. This low exemption threshold — compared to $13+ million for U.S. citizens — makes entity structuring essential for most international buyers. Purchasing through a properly structured foreign corporation or trust can mitigate or eliminate this exposure.
Foreign sellers pay federal capital gains tax on any profit from the sale of U.S. real property, plus applicable state and local taxes. The federal rate depends on the holding period and the seller's tax bracket. In New York, state and city capital gains taxes apply on top of the federal rate. In Florida, there is no state-level capital gains tax.
Despite the complexity of U.S. taxation and the cost of entry into markets like Manhattan, international buyers continue to allocate capital to American luxury real estate. The reasons are consistent and enduring:
The United States is not the only destination for international real estate investment, but it remains the most open, most transparent, and most liquid. For buyers who value these qualities, the case for U.S. luxury real estate remains compelling.
Get our comprehensive guide to purchasing U.S. real estate as an international buyer — covering taxes, FIRPTA, entity structures, financing, and more.
Download the GuideYes. There are no restrictions on foreign nationals purchasing residential or commercial real estate in the United States. You do not need U.S. citizenship, a green card, or any particular visa. The United States imposes no foreign buyer taxes or surcharges.
Most international investors purchase through a U.S. LLC, which provides liability protection and simplifies tax reporting. Buyers with significant estate tax exposure may benefit from purchasing through a foreign corporation or trust. The right structure depends on your individual circumstances — professional counsel is essential.
No. Virtual viewings, electronic signatures, and closings via power of attorney are all standard. Many international buyers complete their entire transaction remotely, with their attorney and agent managing the process on their behalf.
Yes. Several U.S. lenders offer mortgage programs for foreign nationals, typically with 30%–50% down payments and documentation requirements that include translated financial statements and bank references. An ITIN or EIN is required.
FIRPTA (the Foreign Investment in Real Property Tax Act) requires the buyer to withhold 15% of the gross sale price when a foreign seller disposes of U.S. real property. This amount is submitted to the IRS as a prepayment of the seller's capital gains tax. Any overpayment is refundable.
Both markets offer compelling advantages for international buyers, but they serve different objectives. NYC offers stability and prestige; Miami offers tax efficiency and growth. Many buyers purchase in both. For a detailed comparison, read our guide: NYC vs Miami Real Estate for International Buyers.
Florida enacted Senate Bill 264 in 2023, which restricts property purchases by nationals from seven designated countries: China, Russia, Iran, North Korea, Cuba, Venezuela, and Syria. The law was upheld by the Eleventh Circuit Court of Appeals and remains in effect. Buyers from other countries face no restrictions.
Our international team has guided buyers from more than 35 countries through the U.S. luxury real estate process. We are ready to help you.
Connect With Our TeamQuestions? Email us directly or call +1-646-376-8752