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How Real Estate Sponsors Can Access Pool of Global Investors and Improve Tax Efficiency

By Driscoll R. Ugarte and Anastasios G. Kastrinakis
July 31, 2025

Raising capital for real estate investments can be a challenge — especially when seeking funding from outside the United States. However, with the right strategy, real estate sponsors — and the developers they often partner with — can access a broader pool of global investors and significantly improve tax efficiency.

This unique approach combines a C-corporation structure with portfolio interest exempt notes — debt instruments that allow U.S. borrowers to pay interest to foreign investors without triggering U.S. withholding tax. To qualify, the notes must be in registered form and cannot be held by a 10% or greater shareholder of the issuing entity, in addition to certain other conditions being met.

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