Blocker Structures

A “blocker structure” is a company that helps investors avoid certain U.S. taxes. It stops income from affecting foreign investors’ taxes by using a U.S. corporation to block the income flow. Investors must hold their stakes through entities taxed as corporations to prevent this income. However, the blocker corporation itself is subject to U.S. taxes, and any dividends may face U.S. withholding taxes. So, while it saves investors from filing U.S. tax returns, the blocker’s taxation can be similar to or higher than what investors would face without it.