but,

A. FOREIGN CORPORATION Foreign investors who invest through a foreign corporation should avoid the U.S. estate tax (and most state death taxes). 

B. U.S. CORPORATION WITH FOREIGN CORPORATION PARENT Favorable U.S. income and estate tax treatment may be found through a structure where a U.S. corporation owned by a foreign corporation purchases income-producing real estate.This structure avoids both the estate tax and the branch profits tax.