The proposal on the partial limitation of the interest deduction is for C corporations.The 20% corporate tax rate proposal does not eliminate double taxation (although they plan to consider methods to reduce it).A potential large impact to certain real estate investors is the proposal to lower the pass-thru entity tax rate to 25%. 

And if so, is there any structure he could set up that could avoid double taxation on a one time Canadian part investor (who is not a member of the LLC nor on the deed of the property) on a single project ?

It can be a scary process since the rules are very specific and there is a lot of money in tax at stake. 

@Waldy CornielLLC Tax Benefits for Rental PropertyOne of the major advantages of using a limited liability company for your rental property is pass-through taxation.This means that the LLC does not pay taxes; the business owner pays the taxes, thus eliminating the double taxation that occurs if you were to form a corporation instead.

When the non resident has paid this tax at closing, then and only then can the non resident file a tax return in New York state for the tax year the home was sold using the (sale price - the cost basis) method of establishing the true "gain" and apply for a refund from the tax that was paid at closing. 

Realize that while you may be paying tax at your ordinary icome rate, at least you will be keeping the remaining $0.60 on the dollar. 

With that said, below are some tips on how to find a local CPA.Your first choice should be to find a CPA that specializes in real estate taxation and one that is local.

Investing rules and taxation are very different as a result. 

The IRA pays the tax at trust tax rates, which can ramp up as high as 37%, but most investors don't get to that level.  

The case does not in any way: (i) prohibit the practice of buying real estate as an entity purchase, (ii) address the failure of the seller in the Palmer House case to pay a conveyance tax at the time of recording the deed, or (iii) mandate reporting of drop and swap or entity purchase transactions for conveyance tax and/or real property valuation purposes."