Why the legitimate legal and tax planning that protects high-net-worth US property owners, including LLCs, family trusts, and offshore companies, becomes the exact barrier the conventional US lending system uses to deny equity release, and how GMG lends against the structure rather than demanding you dismantle it.
You did everything right.
When you acquired your US property, whether a Manhattan condominium, a Beverly Hills estate, a Miami waterfront residence, or a Hamptons weekend house, you took legal and tax advice. Your advisors recommended holding the property through a structure that would protect personal liability, facilitate estate planning, simplify generational transfer, and optimise the tax treatment. You followed that advice. You established a US LLC, a Delaware holding company, a family trust, or an offshore vehicle in the British Virgin Islands or the Cayman Islands.
Now, years or decades later, the property has appreciated significantly. You need to release equity. You approach a US bank. And the conversation hits a wall.
The lender will not extend an equity release facility to an LLC. Or the trust is the wrong type for their underwriting system. Or the offshore holding company is too complex for their compliance team. Or they will proceed, but only if you transfer the property into personal name first, which is an instruction to undo the legitimate planning you paid to create, potentially triggering tax consequences in the process.
GMG does not require you to dismantle your legal planning to release your equity. We extend equity release facilities against the structure.
This is Part 8 of UNLOCKED IN AMERICA, an 11-part series for international high-net-worth owners of US real estate who have built extraordinary wealth in America and cannot access it. For a full overview of how the facility works, visit GMG's US property equity release programme.
Why High-Net-Worth US Property Owners Use Structures, and Why Those Structures Block Conventional Equity Release
The structures that international high-net-worth families use to hold US property exist for sound legal and tax reasons. They were established on professional advice. They serve legitimate purposes. And they are the precise reason that the conventional US equity release market turns these families away.
The US LLC for Liability Protection and Privacy
LLCs separate the property's liability exposure from the owner's personal assets and, in most US states, prevent the beneficial owner's name from appearing on public land records. For internationally mobile high-net-worth owners who value both liability protection and discretion, LLCs are the standard holding vehicle. According to the American Bar Association, LLC ownership of investment real estate is among the most widely recommended structures in US estate and property planning precisely because of this combination of protection and flexibility.
The Family Trust for Estate Planning and Generational Transfer
Family trusts avoid probate on the owner's death, enable seamless transfer to beneficiaries, facilitate generation-skipping planning, and provide asset protection. For internationally mobile high-net-worth property owners, a US family trust accommodates the complexity of a financial life that extends across multiple jurisdictions. The trust does everything it was designed to do, until the owner tries to access a conventional equity release facility.
Offshore Holding Companies for International Tax Efficiency
Internationally mobile high-net-worth buyers, particularly non-US residents who own US property as an investment, have historically used BVI, Cayman Islands, or Panama holding companies to manage US estate tax exposure. This was standard practice for international high-net-worth US property buyers throughout the 1980s, 1990s, and early 2000s. The same structures that made perfect legal and tax sense then are the precise structures that the conventional US equity release market will not lend against today.
The IRS guidelines on foreign ownership of US real property confirm that offshore holding structures for US real estate remain a legitimate and widely used approach for managing FIRPTA obligations. The existence of the structure is not a tax problem. It is a conventional lending problem, and it is one that GMG was built to solve.
How GMG Extends Equity Release Against Structured US Property Ownership
GMG's equity release programme is specifically designed to lend against the structures that conventional US lenders decline. Each structure type has its own assessment process, and in every case the approach is to work within the structure rather than around it.
US LLCs
GMG extends equity release facilities to US LLCs. We assess the LLC as the borrowing entity, take security against the property held by the LLC, and require personal guarantees from the LLC's beneficial owners. No restructuring and no property transfer required. The LLC continues to serve its liability protection and privacy functions throughout the equity release period.
For families considering the longer-term financing picture after equity release, GMG's resource on equity release for long-term US property owners covers how LLC-held properties transition from the short-term equity release facility into permanent financing through America Mortgages.
US and Domestic Family Trusts
GMG extends equity release against US property held in revocable living trusts and, on a case-by-case basis, irrevocable trusts. For revocable trusts the process is straightforward. For irrevocable trusts the trust terms and beneficiary structure are reviewed to ensure the equity release security interest can be properly perfected. In most cases, irrevocable trust equity release can proceed without modification to the trust instrument.
Offshore Holding Companies
GMG has extensive experience extending equity release facilities against properties held by BVI Ltd companies, Cayman Islands LPs and LLCs, Panama SAs, Liechtenstein foundations, and comparable entities. Full beneficial ownership disclosure to the ultimate individual level is required, consistent with regulatory obligations, along with personal guarantees from qualifying beneficial owners. The offshore structure remains in place throughout.
For families with children approaching US university age, GMG's dedicated resource on education and US property equity explains how equity released from LLC or trust-held US property can fund both university costs and a next-generation US property acquisition, often the most tax-efficient way to use the facility.
Key Equity Release Parameters
- Loan size: USD 500,000 to USD 20,000,000+
- Term: 6 to 24 months
- LTV: Up to 65 to 70% of independently appraised US market value
- Interest: Retained or rolled up, no monthly payment in most structures
- Borrower entity: US LLC, US family trust, US LP, BVI Ltd, Cayman LLC or LP, Panama SA, and comparable offshore entities subject to due diligence
- Personal guarantee: Required from ultimate beneficial owners in most cases
- No ownership restructuring required as a condition of equity release
- Timeline: Standard structures 10 to 20 business days; complex structures 20 to 35 business days
For long-term financing after the equity release period, America Mortgages provides Foreign National and DSCR mortgage products designed to accommodate LLC, trust, and offshore entity ownership across all 50 US states.
The Wall Street Journal has reported on the growing frustration among high-net-worth property owners whose legitimate holding structures create unnecessary friction with conventional US lenders, describing it as one of the most common and avoidable barriers in American property finance.
"We see this situation regularly. A high-net-worth family has done exactly the right thing, held their US property through a well-structured LLC or offshore trust, kept the planning current, done everything their advisors recommended. And then they find that the structure that protected them for twenty years is the thing the bank is using to decline their equity release application. We are set up to extend equity release against the structure, not around it."
— Donald Klip, Co-Founder, Global Mortgage Group and America Mortgages
Is This Right for You?
This solution is most relevant if:
- You own US property held through a US LLC, a family trust, a US LP, or an offshore holding company
- You have been declined for US equity release finance because the lender will not extend a facility to your holding entity
- You have been told you need to transfer the property into personal name before any equity release can proceed
- The equity in the property is substantial and the capital need is real
- You want to release equity without dismantling the legal and tax planning you have put in place
Contact Donald Klip
If you are an international high-net-worth owner of US real estate and want to explore equity release or a bridging loan against your American property, contact Donald Klip directly.
Email: [email protected]
Phone: +65 9773-0273
Website: gmg.asia
America Mortgages: americamortgages.com
To receive an indicative equity release term sheet, we need only: US property address and type, estimated current market value, any existing mortgage balance, approximate equity release amount required, desired loan term, holding entity type and jurisdiction, and a brief description of the intended use of funds and repayment plan.
Continue reading the UNLOCKED IN AMERICA series at gmg.asia.
