The Complete Equity Release Guide for International High-Net-Worth Owners of US Real Estate Held Through Jersey Trusts, BVI Companies, Cayman Structures, Liechtenstein Foundations, Panama Corporations, and Other Offshore Vehicles
How globally mobile high-net-worth individuals and families who hold American real estate through offshore holding structures, and the corporate services firms, trust companies, law firms, and fiduciary services providers in Jersey, Guernsey, BVI, Cayman, Liechtenstein, Luxembourg, Panama, Singapore, Hong Kong, and other offshore financial centres who manage those structures, can access equity release finance against US real estate without dismantling the legal and tax planning that makes those structures valuable
The offshore structure holding US real estate is one of the most consistent and most strategically important configurations in the global high-net-worth property ownership landscape. It is not an exotic arrangement. It is not a red flag. It is the standard, rational, and legally sound approach to international real estate investment taken by high-net-worth families across every country and every asset class.
A British family holds their Hamptons estate through a Jersey discretionary trust established in 1987 for estate planning purposes. A German business family holds their Aspen property through a Liechtenstein Anstalt that manages the family's international real estate portfolio alongside a broader wealth structure. A Chinese high-net-worth family holds their Beverly Hills home through a BVI company that was incorporated to navigate China's capital control environment. A Latin American family holds their Miami condominium through a Cayman Islands LP established for asset protection and confidentiality. A Swiss family office holds a portfolio of US properties — Manhattan, Florida, and California — through a Luxembourg SOPARFI as part of a broader European wealth management structure. A Japanese corporation holds its Hawaii resort property through an offshore vehicle established in the late 1980s at the time of the original acquisition.
Every one of these structures is legitimate. Every one of them serves a genuine and important purpose, estate planning, asset protection, tax efficiency, generational wealth transfer, capital control navigation, or simply the standard international best practice for holding significant international real estate assets. And every one of them is the precise reason that the conventional US equity release market will not lend against the property.
The conventional US mortgage and home equity lending market was built for the domestic American property owner with a personal name on the deed, a Social Security Number, a W-2 income, and a FICO credit score. An offshore company, trust, or foundation as the registered owner of a US property is, from the conventional US lender's perspective, an immediate and usually final barrier to equity release. Not because the structure is illegitimate. Not because the underlying property lacks value or the beneficial owner lacks financial strength. But because the conventional US lending system does not have the compliance framework, the legal expertise, or the credit assessment methodology to extend equity release facilities to offshore entities holding US real estate.
Global Mortgage Group does.
Our equity release programme has been built specifically and intentionally to serve international high-net-worth owners of US real estate, including and especially those who hold their American property through the offshore structures that make up the standard architecture of internationally mobile high-net-worth wealth management. We lend against BVI companies. We lend against Cayman trusts and LPs. We lend against Jersey trusts. We lend against Liechtenstein Anstalts and Stiftungs. We lend against Luxembourg holding companies. We lend against Panama corporations. We lend against Hong Kong limited companies. We lend against Singapore private limited companies and Variable Capital Companies. Subject to thorough and efficient beneficial ownership due diligence, we assess the US property value and the exit strategy, not the nationality of the beneficial owner, not the jurisdiction of incorporation, and not the complexity of the holding structure.
This article is written for two audiences. The first is the international high-net-worth beneficial owner who holds US real estate through an offshore structure and who wants to release equity from that US property without being told, again, that their holding structure is the reason the bank cannot help. The second is the corporate services firm, trust company, law firm, fiduciary services provider, or family office adviser in Jersey, Guernsey, BVI, Cayman, Liechtenstein, Luxembourg, Panama, Singapore, Hong Kong, or any other offshore financial centre who manages client structures that hold US real estate and who wants to establish a working relationship with a lender who can actually serve those clients.
This is the Unlocked in America: Offshore Structures guide, part of the Unlocked in America series by Global Mortgage Group and America Mortgages, the only US mortgage lender focused exclusively on overseas borrowers.
Why Offshore Structures Hold US Real Estate: The Legitimate Reasons
Before addressing the equity release solution, it is worth being explicit about why offshore structures hold US real estate, because the conventional US lending system's refusal to engage with these structures often implies a suspicion that is not warranted.
Estate planning and generational wealth transfer
The most common reason that international high-net-worth families hold US real estate through offshore trusts and foundations is estate planning. The United States imposes federal estate tax on US-sited assets held by non-resident aliens at rates of up to 40% — with a non-resident alien exemption of only USD 60,000 compared to the USD 12 million+ exemption available to US citizens and residents. A non-resident international high-net-worth family that owns USD 5 million of Manhattan real estate in personal name faces a potential US federal estate tax liability of nearly USD 2 million on the death of the beneficial owner. Holding the same property through an offshore company or trust, properly structured with qualified US tax advice, can significantly reduce or eliminate this exposure.
Jersey trusts, Guernsey trusts, Cayman trusts, Liechtenstein foundations, and BVI companies are the standard vehicles for this estate tax planning, not because they are exotic or aggressive, but because they are the internationally recognised legal instruments that qualified US international tax attorneys recommend to their non-resident clients as the appropriate holding structure for significant US real estate.
Asset protection
Offshore holding structures provide a layer of asset protection, separating the US real estate from the personal liability exposure of the beneficial owner in ways that a direct personal ownership cannot. For internationally mobile high-net-worth individuals operating in markets where litigation risk, political risk, or counterparty risk is elevated, the asset protection afforded by an offshore trust or company holding a US property is a genuine and material benefit.
Capital control navigation
For high-net-worth buyers from countries with capital control regimes: China, Vietnam, Brazil, Venezuela, Indonesia, the offshore holding structure is often the mechanism through which US real estate was legally acquired in the first place. Capital that was lawfully accumulated outside the home country, through legitimate business activities, international trade, or prior offshore investment, is held in offshore entities that then acquire US real estate directly. The offshore structure is not a mechanism for evading capital controls, it is the vehicle for deploying lawfully held offshore capital into a US asset.
Privacy and confidentiality
Many offshore jurisdictions do not require public disclosure of the beneficial owners of companies, trusts, or foundations incorporated within them. For internationally mobile high-net-worth individuals, including those for whom public disclosure of US real estate ownership could create security risks, business risks, or personal privacy concerns, the confidentiality of an offshore holding structure is a genuine and legitimate benefit.
Tax efficiency
Offshore holding structures can provide legitimate tax efficiency in the way that income from US real estate, rental income, management fees, service fees, is treated under applicable tax treaties and domestic law. A properly structured offshore holding for US real estate, with qualified US and home-country tax advice, can minimise double taxation and optimise the after-tax return from US real estate investment. This is legal tax planning, not evasion.
GMG does not make judgements about which of these purposes motivated a specific client's use of an offshore structure. We conduct thorough beneficial ownership due diligence to establish who ultimately owns the US property, and then we assess the equity release on the basis of the property value and the exit strategy.
The Four Offshore Structure Types: How GMG Assesses Each
The offshore structures that hold US real estate fall into four primary categories — trusts, companies, foundations, and partnerships, each with its own legal character, its own beneficial ownership framework, and its own equity release assessment approach.
Offshore Trusts
The offshore trust, whether a Jersey discretionary trust, a Guernsey interest-in-possession trust, a Cayman Islands STAR trust, a Cook Islands asset protection trust, or any other internationally recognised trust vehicle, is the most sophisticated and most legally complex offshore structure type from an equity release lending perspective.
In a trust, legal title to the US property vests in the trustee, the trust company or professional trustee that administers the trust in accordance with the trust deed. The beneficial owners — the beneficiaries, do not hold legal title and cannot typically grant security over the trust property without the trustee's cooperation and in many cases without the consent of the protector or advisory committee.
For equity release lending against a US property held in an offshore trust, GMG requires:
The trustee's cooperation and authority: The trustee must have the power under the trust deed to mortgage or charge the US property as security for the equity release facility. We review the trust deed, or a legal opinion from qualified trust counsel confirming the trustee's power, before proceeding.
Beneficial ownership disclosure: We require disclosure of the beneficial owners of the trust to the individual level, the settlor, the beneficiaries (named or by class), and the protector where applicable. This disclosure is provided to GMG on a confidential basis and is not shared with third parties beyond what is required by applicable AML regulations.
Personal guarantee from qualifying beneficial owners: In most cases GMG requires a personal guarantee from one or more of the principal beneficiaries as a condition of the equity release facility, providing an additional layer of security beyond the US property itself.
Trust deed review and legal opinion: A legal opinion from qualified US counsel confirming that the trustee has the power to grant the security interest, that the security interest will be properly perfected against the US property, and that the equity release will not contravene the terms of the trust deed.
The most common offshore trust structures that GMG has experience lending against include: Jersey discretionary trusts, Guernsey trusts, Isle of Man trusts, Cayman Islands trusts and STAR trusts, BVI trusts, Bahamas trusts, Cook Islands trusts, and Liechtenstein Stiftungs operating as charitable and private foundations.
Offshore Companies
The offshore company, whether a BVI Business Company, a Cayman Islands exempted company, a Jersey company, a Panama SA, a Hong Kong limited company, a Singapore private limited company, or any other international corporate vehicle, is the most widely used and most straightforward offshore structure type for US real estate equity release lending.
In an offshore company holding structure, the company is the registered owner of the US real estate, appearing on the deed as the titleholder, with the equity release security interest granted by the company as borrower and perfected against the US property in accordance with the laws of the state in which the property is located.
For equity release lending against a US property held through an offshore company, GMG requires:
Corporate authority: Confirmation that the company's directors have the corporate authority to grant the security interest, through board resolutions and in some cases shareholder resolutions depending on the company's constitutional documents.
Beneficial ownership disclosure: Full beneficial ownership disclosure to the individual level, the ultimate individual shareholders who own the offshore company, through whatever chain of intermediate ownership exists.
Personal guarantee: In most cases a personal guarantee from the ultimate individual beneficial owners, or from qualifying guarantors with sufficient personal net worth to support the guarantee.
Certificate of good standing and corporate documentation: Current certificate of good standing from the jurisdiction of incorporation, the company's memorandum and articles of association, register of members, and register of directors.
The most common offshore company structures that GMG has experience lending against include: BVI Business Companies, Cayman Islands exempted companies, Jersey companies (private and public), Guernsey companies, Isle of Man companies, Panama SAs, Hong Kong limited companies, Singapore private limited companies, Luxembourg SARLs and SOPARFIs, Netherlands BVs, Cyprus limited companies, Bahamas IBCs, Bermuda exempted companies, and Curaçao NVs.
Offshore Foundations
The offshore foundation, whether a Liechtenstein Stiftung, a Liechtenstein Anstalt, a Panama Foundation, a Seychelles Foundation, or a Bahamas Purpose Trust operating as a quasi-foundation, is a civil law vehicle with no direct common law equivalent that combines elements of a trust and a company in a single vehicle.
The Liechtenstein Anstalt and Stiftung are the most commonly encountered foundation-type structures in the context of US real estate held by German, Swiss, and Eastern European high-net-worth families. The Panama Foundation (Fundación de Interés Privado) is the most commonly encountered foundation-type structure for Latin American high-net-worth families.
Foundation structures for equity release require specialist legal assessment in both the foundation's home jurisdiction and in the US state where the property is located. GMG works with qualified counsel in Liechtenstein, Panama, and other foundation jurisdictions to assess the equity release lending capability and the security perfection methodology on a case-by-case basis.
Offshore Partnerships and Limited Partnerships
The offshore limited partnership, whether a Cayman Islands LP, a Delaware LP with offshore partners, a Jersey LP, or any other international partnership vehicle, is commonly used by institutional and semi-institutional international high-net-worth investors to hold US real estate as part of a managed investment portfolio.
Cayman Islands LPs and Delaware LPs with offshore general partners are particularly common structures for US real estate held by family office-managed portfolios and by investor groups that have pooled capital for US property investment. GMG assesses equity release lending against US properties held through offshore LP structures on a case-by-case basis, working with the general partner to assess the partnership's authority to grant security over the US property.
The Professional Intermediary Relationship: How GMG Works with Corporate Services, Trust Companies, Law Firms, and Fiduciary Services Providers
A significant proportion of GMG's largest equity release transactions have originated from professional referrals, corporate services firms, trust companies, law firms, and fiduciary services providers who manage offshore structures holding US real estate and who have identified a client need for equity release that the conventional US lending market cannot serve.
This referral relationship is one of the most important and most valued components of GMG's business development approach. The professional intermediary who manages a client's offshore structure is frequently the first person to become aware of a client's equity release need, because the client discusses their capital requirements with their trusted structure manager before approaching a bank. And the professional intermediary who can introduce that client to a lender that actually works, that can lend against the structure rather than demanding it be dismantled, delivers genuine and material value to the client relationship.
GMG works with professional intermediaries in the following offshore financial centres:
Jersey and Guernsey: Jersey's trust company and corporate services industry, including the major trust companies (Intertrust, Vistra, Sanne, Aztec Group, Ogier, Carey Olsen, and their peers) and the specialist fiduciary services firms, manage a significant volume of client structures holding US real estate. GMG works with Jersey and Guernsey-based trust companies and law firms to provide equity release facilities for their clients whose US property is held through Jersey or Guernsey trusts and companies.
British Virgin Islands: The BVI's corporate services industry, the registered agents, corporate services providers, and law firms (Harneys, Maples, Ogier, Conyers, and their peers) — manages the largest concentration of offshore company holding structures for US real estate of any jurisdiction. A BVI registered agent or corporate services provider who identifies a client BVI company holding US real estate where the beneficial owner has expressed an equity release need can refer that client to GMG with confidence that the BVI structure will not be a barrier to proceeding.
Cayman Islands: Cayman's financial services industry, the major fund administrators, trust companies, law firms (Maples, Walkers, Ogier, Conyers, and their peers), manages significant Cayman LP and trust structures holding US real estate. GMG works with Cayman-based professional service firms to provide equity release solutions for clients whose US real estate is held through Cayman structures.
Liechtenstein: Liechtenstein's fiduciary services industry, the Treuhänder firms and law firms that administer Anstalt and Stiftung structures, manages European high-net-worth wealth including significant US real estate holdings. GMG works with Liechtenstein fiduciary services providers to assess equity release against US properties held through Liechtenstein foundation and company structures.
Luxembourg: Luxembourg's fund administration and holding company services industry manages European family office and institutional structures including US real estate holdings. GMG works with Luxembourg-based administrators and advisers to provide equity release solutions for US properties held through SOPARFI and other Luxembourg structures.
Singapore: Singapore's family office ecosystem, the single and multi-family offices, the private banks, the licensed fund management companies, and the Variable Capital Company (VCC) framework, manages an extraordinary concentration of Asian and global high-net-worth capital including significant US real estate positions. As a Singapore-headquartered firm, GMG has direct relationships with Singapore's professional services community and is the natural equity release partner for Singapore-based advisers managing client structures with US real estate exposure.
Hong Kong: Hong Kong's trust company and corporate services industry manages significant Hong Kong and mainland Chinese high-net-worth capital including substantial US real estate holdings. GMG works with Hong Kong-based trustees, corporate services providers, and law firms to provide equity release solutions for clients whose US real estate is held through Hong Kong company structures.
Panama: Panama's corporate services industry, the law firms and registered agents that administer Panama SA structures, manages significant Latin American high-net-worth capital including US real estate held through Panama corporations. GMG assesses equity
release lending against US properties held through Panama SA structures subject to AML and beneficial ownership due diligence.
Other jurisdictions: GMG assesses equity release lending against US real estate held through structures in the Isle of Man, Labuan, Bermuda, Bahamas, Barbados, Curaçao, Cyprus, Malta, Netherlands, Ireland, Monaco, Switzerland, Cook Islands, and other offshore and onshore financial centres, on a case-by-case basis with appropriate legal assessment in each jurisdiction.
The Beneficial Ownership Due Diligence Framework
GMG's equity release assessment for offshore structure holdings is built around a thorough and efficient beneficial ownership due diligence framework that identifies the ultimate individual beneficial owner of the US property and assesses the equity release on that basis.
Our due diligence framework requires:
Ultimate beneficial ownership disclosure: Identification of the natural person or persons who ultimately own or control the offshore structure, through whatever chain of corporate, trust, or foundation ownership exists. This disclosure is made to GMG on a confidential basis.
Source of funds: Confirmation of the legitimate source of the funds used to acquire the US property, whether from business income, investment returns, property sale proceeds, inheritance, or other legitimate sources.
Structure documentation: The constitutional documents of the offshore entity, memorandum and articles of association, trust deed, foundation charter, partnership agreement, together with any supplementary documentation confirming the entity's authority to grant security over the US property.
US legal assessment: A legal opinion from qualified US counsel in the state where the property is located confirming that the security interest can be properly perfected against the US property held through the offshore structure.
AML screening: Standard AML and sanctions screening of the ultimate beneficial owners and the offshore entity, including OFAC screening for all borrowers regardless of nationality.
Professional intermediary representation: Where the equity release is introduced through a professional intermediary, GMG welcomes a letter of representation from the intermediary confirming the client relationship and the intermediary's own AML and KYC assessment of the client structure.
GMG's due diligence framework is designed to be thorough without being disproportionate. We understand that the offshore structures that hold international high-net-worth US real estate are typically administered by professional service firms with their own rigorous AML and KYC frameworks, and that the due diligence work already done by the trustee, the corporate service provider, or the law firm is relevant context for our own assessment. Where a professional intermediary has already conducted comprehensive KYC on a client structure, we work with that intermediary to build on the existing due diligence rather than starting from scratch.
The Equity Release Parameters for Offshore Structure Holdings
Global Mortgage Group provides senior secured equity release facilities against qualifying US residential and commercial real estate held through offshore structures — assessed on property value and exit strategy rather than on personal income documentation, US credit history, or the jurisdiction of the holding structure.
Key equity release parameters:
- Loan size: USD 500,000 to USD 100,000,000+
- Term: 6 to 24 months
- LTV: Up to 65–70% of independently appraised US market value for residential property; up to 60–65% for commercial and specialist property
- Interest: Retained or rolled up — no monthly payment obligation in most structures
- Borrower entity: BVI Business Companies, Cayman Islands exempted companies and LPs, Jersey companies and trusts, Guernsey companies and trusts, Isle of Man companies and trusts, Liechtenstein Anstalts and Stiftungs, Luxembourg SARLs and SOPARFIs, Panama SAs and Foundations, Hong Kong limited companies, Singapore private limited companies and VCCs, Netherlands BVs, Cyprus limited companies, Bahamas IBCs, Bermuda exempted companies, Curaçao NVs, Cook Islands trusts, and all other qualifying international holding structures subject to beneficial ownership due diligence
- Personal guarantee: Required from ultimate individual beneficial owners in most cases — or from qualifying guarantors acceptable to GMG
- US legal assessment: Required in all cases — GMG works with a panel of qualified US counsel across all major US states
- AML and beneficial ownership due diligence: Conducted thoroughly and efficiently — the professional intermediary's existing KYC is relevant context
- OFAC screening: Conducted for all borrowers regardless of nationality or jurisdiction
- Security: US residential and commercial property in all major US markets — New York, California, Florida, Texas, Hawaii, Colorado, and beyond
- Timeline: Standard structures 10–20 business days from complete documentation; complex structures including trusts and foundations 20–35 business days
For long-term financing after the equity release period, America Mortgages provides Foreign National mortgages, DSCR investment property mortgages, and EXPat mortgages for US citizens living abroad, all available to borrowers holding US property through qualifying offshore structures, subject to appropriate legal assessment.
The Most Common Equity Release Scenarios for Offshore Structure Holdings
Capital need at the beneficial owner level where the structure holds the asset
The most common offshore structure equity release scenario: the beneficial owner needs capital, for a further property acquisition, a business investment, a family obligation, or a portfolio rebalancing, but the asset that could fund that need is held inside an offshore structure. The conventional lending market will not lend against the structure. GMG will.
Generational transition and estate restructuring
As the original settlors and beneficial owners of offshore structures established in the 1980s and 1990s age and begin generational wealth transfer, the structures holding US real estate frequently need to be restructured, distributed, or wound down. Equity release against the US property during this transition period provides the liquidity to manage the process — funding estate duty obligations, equalising distributions among multiple beneficiaries, or
bridging the gap between the current structure and the new one, without forcing a property sale at an inopportune moment.
Refinancing offshore structure holdings onto long-term mortgages
Many offshore structure holdings were acquired without mortgage finance, paid entirely from the offshore capital that funded the structure's international investment mandate. As those structures mature and as the beneficial owners' financial planning evolves, the introduction of long-term mortgage finance against the US property can free up offshore capital for other purposes without requiring a property sale. GMG's equity release facility provides the bridge; America Mortgages' Foreign National or DSCR mortgage product provides the long-term structure.
Completion funding for off-plan acquisitions held through offshore structures
Off-plan US property acquisitions, branded residences, luxury condominium developments, that were committed to through offshore structures and that now face completion payment calls can be funded through GMG's equity release facility against the existing US property held in the same or a related offshore structure.
A Note to Professional Intermediaries
If you are a trust company director, a corporate services provider, a fiduciary services professional, a family office adviser, or a law firm partner in Jersey, Guernsey, BVI, Cayman, Liechtenstein, Luxembourg, Singapore, Hong Kong, Panama, or any other offshore financial centre, and you manage client structures that hold US real estate, this section is written specifically for you.
GMG's equity release programme is one of the very few financing solutions available to your clients whose US real estate is held through offshore structures. We understand that your clients frequently come to you with capital needs that cannot be met by the conventional US lending market, and that the standard answer from US banks is that the offshore structure is a barrier to lending. We exist to change that answer.
We work with professional intermediaries on a referral basis. We do not compete with the advisory, trust administration, or corporate services relationship, we complement it by providing the financing component that the structure requires. We are happy to discuss specific client situations on a no-names basis to give you a preliminary view of whether equity release is feasible before you introduce the client formally.
We understand confidentiality. We understand the importance of maintaining the integrity of the client's existing structure and advisory relationships. And we understand that the professional intermediary relationship is built on trust, which is why we operate with the discretion and the professionalism that offshore financial centre practitioners expect from their counterparties.
If you would like to discuss establishing a referral relationship with GMG, or if you have a specific client situation you would like to discuss, contact Donald Klip directly.
Contact Donald Klip
For international high-net-worth beneficial owners of US real estate held through offshore structures:
Email: [email protected]
Phone: +65 9773-0273
Website: gmg.asia
America Mortgages: americamortgages.com
For professional intermediaries, trust companies, corporate services providers, law firms, and fiduciary services professionals, who manage offshore structures holding US real estate and who want to discuss a referral relationship or a specific client situation:
Email: [email protected]
Phone: +65 9773-0273
To receive an indicative equity release term sheet for a US property held through an offshore structure, we need: US property address and type, estimated current market value, any existing mortgage or charge over the property, approximate equity release amount required, desired loan term, offshore structure type and jurisdiction of incorporation or establishment, and a brief description of the intended use of funds and repayment plan.
No personal US income documentation required. No US credit history required. No Social Security Number required. Beneficial ownership disclosure and AML documentation required as standard. Learn more.
Continue reading the Unlocked in America series at gmg.asia.
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Jurisdiction Reference Table: Offshore Structures and GMG Equity Release Capability
Global Mortgage Group | gmg.asia | americamortgages.com | [email protected] | +65 9773-0273
| Jurisdiction | Common Structure Types | GMG Assessment Capability |
| Jersey | Discretionary trust, company, foundation, LP | Full — extensive experience |
| Guernsey | Trust, company, LP | Full — extensive experience |
| Isle of Man | Trust, company | Full |
| British Virgin Islands | Business Company (BC), trust | Full — most common structure |
| Cayman Islands | Exempted company, LP, STAR trust | Full — extensive experience |
| Bermuda | Exempted company, trust | Full |
| Liechtenstein | Anstalt, Stiftung, AG | Full — specialist legal assessment required |
| Luxembourg | SARL, SOPARFI, SCSp | Full |
| Netherlands | BV | Full |
| Switzerland | AG, GmbH, family office | Full |
| Monaco | SAM, holding structures | Case by case |
| Cyprus | Limited company | Full |
| Malta | SICAV, company | Full |
| Ireland | Holding company, QIAIF | Full |
| Panama | SA, Fundación de Interés Privado | Full — AML due diligence required |
| Bahamas | IBC, purpose trust | Full |
| Barbados | International business company | Full |
| Curaçao | NV | Full |
| Turks and Caicos | IBC | Full |
| Hong Kong | Limited company | Full — most common Asian structure |
| Singapore | Private limited company, VCC, family office | Full — GMG headquarters |
| Cook Islands | Trust | Case by case |
| Vanuatu | Company | Case by case |
