In November, Republican members of Congress and the Trump administration unleashed a tax reform plan, aimed at simplifying the tax system and cutting the tax rate for business. This impetus for change was directed at middle-class (some say upper-class) Americans and U.S. companies. Left on the sidelines were the large pools of capital interested in investing in U.S. property markets.

None of this has daunted foreign investment in U.S. real estate, but it still makes the United States a more challenging market to place capital, and much of that is due to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), which made some punishing changes for foreign investors: Capital gains from the disposition of U.S. property interests are treated as income and taxed accordingly; foreign investors are required to keep 30 percent of the purchase price as a withholding to cover taxes at sale; and, through a tax incentive, the act aims to keep foreign ownership of REITs at 5 perc