Inbound Investment
Corporations, Blockers, CFCs, and Taxes for Foreign Investors Part 2
Blocker corporations provide a way to mitigate the company’s tax burden.. A blocker structure is treated as a corporation that works to “block” taxable income at the corporate level for U.S. federal, state, and local income tax purposes. The corporate status of the blocker allows all earnings to be taxed at the corporate level rather than at the investor level, until the corporate blocker makes distributions to the investor. Furthermore, a U.S. blocker pays a flat 21% tax on all its income, regardless of the source of the earnings. Additionally, blocker corporations usually pay the U.S. tax themselves, so investors won’t have to.
January 15, 2026
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