A foreign corporate investor in US real property will generally elect for trade or business status, so as to get deductions for expenses. The imposition of the branch tax means that a domestic corporation will generally be preferred to a foreign one. It follows that a US investment will generally require a foreign corporation owning a US corporation owning the US property. This provides immunity to estate tax, though it has an income tax price. An FID carries no tax credit.
Computation can be complex.
A UK foreign income trap company is routinely used to maximise foreign tax credits, deductions for charges and interests being taken by its parent. Greater tax efficiency may require this structure to be duplicated, so that the FID comes out of a stream subject to a higher rate of foreign tax and therefore fully franked with foreign tax credits. The UK offers no exemption from tax on capital gains. The foreign trust legislation was enacted. A tax on expatriates was proposed.