Foreign-corp blocker vs single-member LLC for doing exchanges — which structure is better?
I'm deciding how to hold US rental real estate that I plan to exchange over time. Some people use a foreign corporation 'blocker', others just a single-member US LLC. How do the two compare for doing 1031 exchanges and for FIRPTA? I also care about estate tax since I'm a nonresident. Is there a clear winner, or is it a tradeoff?
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