S-Corp has some extraneous benefits (issued shares, survivability, separate entity), and the option to be taxed pass-through or not (so, no benefit vs an LLC on taxation). 

@Kenneth KussmanHi Kenneth,Here’s a post from BP where someone in your similar situation had some important questions on converting your primary residence into a rental property:https://www.biggerpockets.com/topics/851996There are some important details about this conversion that you should understand (depreciation, amortization, basis calculation, deductions for repairs, homeowners exclusion, active participation rules, to name a few).It’s something that can be researched and done on your own, but I highly recommend using a CPA who understands real estate taxation to prepare your tax return.

First, taxes are paid on the margin so being pushed into a higher tax bracket does not change your total taxation.

I would prioritize finding an accountant who specializes in real estate taxation over one that is local.There are 20+ accountants on this message board who specialize in real estate taxation.

If so, there are 20+ accountants on this site that specialize in real estate taxation.

But a 1031 when completed appropriately by a foreign investor not only defers all of the tax on gain but it also negates the firpta withholding since the gain is not recognized.But as you can imagine the IRS it not excited about letting non-us citizens (or citizens as well come to think about it) walk around with access to money that may be the IRS's by virtue of taxation. 

"Double taxation" is a very smart term that I'm sure came from a focus group somewhere years ago.

You can avoid the taxation by doing a direct rollover of funds and then buy investment property inside of your SDIRA.

I would prioritize finding an accountant who specializes in real estate taxation over one that is local.There are 20+ accountants on this message board who specialize in real estate taxation.

Otherwise, it would be double taxation as with a C Corp.What does that mean?