The law firm of Rackemann Sawyer & Brewster describes the estate tax regime imposed on foreign individuals who own US residential property, which concludes that the 35 % Estate tax rate is charged on the entire value of the property that exceeds USD60,000.

Where that foreign individual owns the same US real estate through either:

1. a Foreign Company or 
2. a Two Tier Partnership Structure 

this US Estate Tax would be Eliminated!