United States

01 · Why Dubai

If you're buying from the US, the appeal of Dubai is real — 0% UAE income tax on rental and gains for individual owners, an AED pegged to the dollar so there's effectively no currency risk for you, and a Golden Visa residency option. But I'll be straight with you up front, because it's the single most important thing for an American buyer to internalise: the United States taxes its citizens and green-card holders on worldwide income no matter where they live or where the asset sits. Moving to Dubai, or holding a UAE residency visa, does not switch that off. So the structuring conversation has to come before the buying conversation for US persons — more so than for any other nationality on this list.

What that means in practice is reporting, on top of whatever US tax applies. Your UAE bank account will almost certainly cross the FBAR threshold (the FinCEN 114 foreign-bank-account report), and FATCA reporting (Form 8938) can apply on top of it. Rental income is reportable on your US return, and a sale is a reportable capital gain to the IRS. There is no comprehensive US-UAE double-tax treaty doing the heavy lifting here, so you don't get automatic relief — you model the yield and the exit as after-US-tax numbers from the start.

The expensive mistake US buyers make is reaching for a non-US holding company to "keep it clean" without US tax advice first. A foreign corporation or fund can drag you into PFIC or CFC treatment — regimes that can turn a simple property into a punitive, paperwork-heavy filing problem. For most US buyers, direct ownership in personal name is the cleaner path precisely because it sidesteps that; a structure should only go in if a US-side adviser has confirmed it helps rather than harms.

Estate planning deserves a deliberate look too. UAE inheritance defaults to Sharia principles for the estate of a foreign owner unless you put a DIFC or ADGM Will in place — and that needs to dovetail with US estate-tax treatment rather than fight it. It's cheap to set up early and painful to retrofit.

On financing, plan for non-resident terms — UAE banks lend to overseas buyers at a more conservative loan-to-value and on heavier documentation than to residents, so many US buyers pay cash or use a developer's off-plan payment plan. Settle the funding route before you commit to a unit.

02 · Golden Visa

The UAE Golden Visa qualifies from AED 2M in real-estate value (verified at DLD valuation). US citizenship is not a barrier — the Visa is granted to non-residents on the property value test. The visa does not change the US tax position; it changes the UAE residency status.

03 · Tax + regulatory questions partner counsel resolves

• Q01Direct ownership in personal name vs an entity — what's the FATCA + FBAR reporting impact?
• Q02If using a non-US entity, does it trigger PFIC or CFC treatment under US tax rules?
• Q03How is rental income taxed under US tax rules + the US-UAE position (no comprehensive DTA)?
• Q04Capital gains on disposal — US treatment, IRS reporting, FIRPTA-equivalent considerations on the US side.
• Q05Estate-planning implications — UAE estate law (Sharia default vs DIFC Wills Service or ADGM Wills Service for non-Muslims) interacting with US estate-tax treatment.

04 · Structuring patterns commonly used

A menu, not a recommendation. The right structure depends on your facts.

• · Direct ownership in personal name — simplest, most common entry mode.
• · ADGM Limited (Abu Dhabi Global Market) corporate vehicle — common-law jurisdiction, English-law contracts.
• · DIFC Foundation (Dubai International Financial Centre) — used for multi-generational estate planning.
• · US LLC indirectly owning the property — possible but requires careful tax structuring.

05 · How partner counsel works

Raj routes US mandates to a US-licensed CPA or tax attorney familiar with cross-border real estate (typically with a UAE presence or a US-UAE structuring practice). Raj coordinates the property side; partner counsel handles the tax + structuring side.

Primary sources

• UAE Golden Visa — ICA Federal Authority →
• IRS — international taxpayers →
• DIFC Wills Service →
• ADGM Foundations & Wills →

Cross-border brief

From United States to Dubai.

Tell Raj what you're looking at and what you already have in place on the United Statesside. He'll coordinate the UAE property work + the partner-counsel referral.