Saudi US Capital
Deals Structuring FIRPTA Sharia Tools Submit Mandate
Analytics Suite

Investment Tools.

Evaluate net yields, FIRPTA exposure, and Sharia compliance thresholds before committing capital.

1. FIRPTA Gross Withholding Estimator

Calculates the 15% statutory IRS withholding on the gross sale price, regardless of net equity.

Net Equity at Sale:
FIRPTA Withholding (15% Gross):
Cash at Closing (Before Fees):

*Assumes direct foreign ownership without a Blocker Corporation.

2. Leveraged Blocker Tax Drag

Estimates US corporate tax liability after stripping income via shareholder debt interest.

Taxable Income (C-Corp):
US Corporate Tax (21%):
Net Repatriated (Interest + Post-Tax):

*Assumes Section 163(j) election out, requires ADS depreciation.

3. Sharia Revenue Tolerance (5% Rule)

Checks if a mixed-use or retail asset breaches the standard 5% threshold for non-compliant revenue (e.g., alcohol, conventional banking).

4. Cash-on-Cash Yield Converter

Translates top-line Cap Rate to levered Cash-on-Cash return.

NOI:
Annual Debt Service:
Cash-on-Cash Return:

5. CFIUS Proximity Screener

Quick check for US zip codes against known Appendix A military installations (Simulated for demonstration).

High Risk: Zip code is near known Part 1 or Part 2 installations. Full Part 802 proximity analysis required.
Low Risk: No major installations detected in immediate vicinity. Standard due diligence applies.

6. Structuring Engine

Determines optimal holding structure based on investor profile.

Recommended Structure:
Direct investment via US LLC to utilize Section 892 exemption from US taxation on non-commercial activities. Leveraged Blocker (Cayman HoldCo -> Delaware C-Corp) to mitigate Estate Tax and ECI. Pass-through LLC with a W-8BEN to accept standard FIRPTA withholding (often lower overall tax drag for short-term capital gains). Domestically Controlled REIT (if US partners hold >50%) or Multi-Tier Blocker.

7. US Estate Tax Exposure

Non-resident aliens only get a $60,000 exemption before facing a 40% estate tax on US-situs assets.

Estimated Estate Tax Risk (40%):

*Mitigated entirely by holding via a foreign corporation.

8. Unrecaptured Section 1250 Estimator

Estimates the tax hit on accumulated depreciation upon sale.

Depreciation taken (straight line 39 yrs):


Tax Liability (25% max rate):

9. SAR to USD Peg Status

3.7500
Peg Maintained

Saudi Arabian Riyal remains officially pegged to the US Dollar, eliminating currency risk for GCC investors deploying into US assets.

10. State Income Tax Checker

Corporate income tax rates in target Sunbelt markets.

  • Texas 0.0% (Franchise Tax only)
  • Florida 5.5%
  • Tennessee 6.5%
  • North Carolina 2.5%