International buyers of Miami real estate pay 4 tax layers: US federal income tax on rental income (graduated rates, ECI election), Florida has no state income tax, Miami-Dade property tax (about 1.8 to 2.2 percent of assessed value annually), and FIRPTA 15 percent withholding at sale. Treaty benefits vary by country; Canada, Mexico, and the UK have favorable provisions. Source: IRS Publication 519, Miami-Dade Property Appraiser.
Every international buyer of Miami real estate needs to understand two tax systems: US federal taxes on US-situated property, and home-country taxes on foreign-owned US assets. How they interact depends on whether your country has a tax treaty with the United States. This guide covers the top 10 source countries for Miami international buyers.
Canada (top-5 source country)
US-Canada tax treaty provides $11.7M estate tax exemption (2026), effectively eliminating US estate tax for most Canadian buyers. Income tax: Canadian residents pay US federal tax on US rental income, claim foreign tax credit on Canadian return to avoid double taxation. FIRPTA 15% applies at sale. Canadians can own Miami property in personal name with minimal US tax inefficiency. For a full breakdown of the snowbird rules, 183-day test, and cross-border financing options, see my complete guide for Canadian buyers in Miami.
United Kingdom
US-UK estate tax treaty also provides high exemptions. Income tax works similarly to Canada: UK residents pay US tax on US-source income, credit against UK tax. UK's own residence-based tax system means UK residents report worldwide income including Miami rental income on UK returns. The 2025 abolition of the UK non-dom regime has increased HMRC's reach on US rental income for all UK residents. For a full breakdown of how the US-UK estate and income tax treaties apply to a Miami purchase, see my complete guide for British buyers in Miami.
Mexico (growing volume)
No comprehensive US-Mexico estate tax treaty. Mexican buyers face US estate tax on Miami property at 40% over $60,000 if held in personal name. LLC structuring is highly recommended for Mexican buyers. Income tax: US-Mexico treaty provides foreign tax credit mechanism for US rental income.
Colombia, Argentina, Venezuela, Brazil
None of these have US estate tax treaties. Personal-name ownership triggers 40% US estate tax over $60K. LLC structuring is essentially mandatory for Latin American buyers to avoid this. Income: each country taxes worldwide income of residents, including Miami rental income. Double-taxation relief depends on country-specific unilateral provisions (typically foreign tax credit on home-country return).
Germany, France, Italy, Spain
EU countries have varying US estate tax treaties. Germany, France, Italy: higher exemptions, moderate friction. Spain: no estate tax treaty, same LLC-structuring recommendation as Latin America. Income: standard foreign tax credit mechanisms. For German buyers, the US-Germany estate treaty offers a pro-rata credit (not the full unified credit), making LLC structuring the practical default for most. The 10-year capital gains exemption under EStG Section 23 is a significant advantage for long-hold German investors. For the full German-specific tax analysis, see my German buyers guide to Miami real estate. For French buyers specifically: the 1978 US-France estate and gift tax treaty provides a pro-rated share of the $15M 2026 unified credit (US assets / worldwide assets x $15M), and IFI wealth tax on worldwide real estate assets above EUR 1.3M net is a key planning consideration. For the full analysis, see my French buyers guide to Miami real estate. For Russian buyers: no US-Russia estate tax treaty exists, leaving only a $60,000 exemption at 40%. A foreign grantor trust (Delaware or Wyoming situs) owning a Florida LLC is the required structure, since a single-member LLC held directly by a Russian national does not eliminate estate tax under IRS disregarded-entity rules. OFAC SDN compliance adds a required pre-purchase step with no equivalent for EU buyers. For the full analysis, see my Russian buyers guide to Miami real estate.
China
No US estate tax treaty. Chinese buyers face the same LLC-structuring imperative as Latin Americans. Additional consideration: Chinese foreign exchange controls require specific export documentation for the purchase funds, handled in coordination with a Chinese tax advisor before wire transfer.
UAE, Saudi Arabia
Most GCC countries have no personal income tax, so home-country income consequences are minimal. US estate tax still applies on US property; LLC structuring recommended for estates over $1M in Miami holdings.
The Common Recommendation Across Countries
For buyers from non-treaty countries (most of Latin America, Middle East, Asia), an LLC owned by a foreign corporation or trust is the default structure to avoid US estate tax exposure. Setup cost: $3,000-$10,000 depending on complexity. This saves hundreds of thousands in US estate tax at death for any holding over $500K. Consult a cross-border CPA familiar with your home country before closing.
"I've closed transactions with international buyers across multiple countries. The ones who arrived with a checklist of specific questions on reserves, deposits, and assignment terms, consistently negotiated better on final terms."Gerardo Gonzalez, Licensed Real Estate Agent at Compass
"The biggest tax mistake I see foreign buyers make is closing in personal name to save $5,000 in setup costs, then paying $400,000 in US estate tax 15 years later because nobody explained the exposure."
Want a country-specific structuring analysis before you close? Reach out and I will connect you with a cross-border CPA who specializes in your home country.
Frequently Asked Questions
Do I pay tax in both countries on my Miami property?
Potentially. Most countries tax residents on worldwide income, so Miami rental income is taxable at home too. US-home-country tax treaties provide foreign tax credit mechanisms to avoid pure double taxation. Your home-country CPA handles the credit.
Which countries have US estate tax treaties?
Countries including Canada, UK, Germany, France, Italy, Japan, Netherlands, and some others. These treaties raise the US estate tax exemption for citizens of those countries substantially. Most Latin American countries do not have these treaties.
Is FIRPTA the same for all countries?
Yes. FIRPTA 15% withholding applies to all foreign sellers regardless of nationality. Tax treaties don't reduce the withholding rate; they affect the final tax owed, which you reconcile via 1040-NR.
Can I use my home-country pension/retirement funds to buy Miami real estate?
Depends on your home-country rules. Most countries restrict pension fund deployment to local investments. Work with a cross-border wealth planner to navigate this.
Does my Miami property count toward my home-country wealth tax?
Yes in countries that have a wealth tax (Spain, Argentina, Colombia, France for some). US assets are generally included in home-country net wealth calculations.
What's the simplest structure for a Latin American buyer?
Foreign corporation -> US LLC -> Miami property. This eliminates US estate tax exposure and provides privacy. Setup: $4,000-$10,000. Ongoing: annual corporate fees, CPA filings.
Frequently Asked Questions
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