Common structure
- Wyoming holding LLC (owns all operating LLCs)
- Property-specific LLCs (one per rental property), each in the state where the property is located OR all in Wyoming and foreign-qualified to operate in the property state
- Asset isolation: each property LLC limits liability to that property
- Privacy: holding LLC owners are not on public filings
Tax treatment for non-residents
- Rental income from US real estate IS US-source income
- Default 30% withholding on gross rent (gross election under Section 871(a))
- Net rent election under IRC Section 871(d) often results in lower tax (allows deductions)
- File Form 1040-NR to claim net rent election
- State income tax may apply in property's state
- Property tax always applies (local)
- Form 5472 + pro forma 1120 for each LLC
Why Wyoming holding plus operating LLC structure
- Wyoming charging-order protection is strongest in US
- Operating LLC in property state simplifies local compliance
- Isolating each property's liability prevents cross-property loss
- Holding LLC provides anonymity layer
- Multi-property scaling is cleaner