So, these investors will need to establish a US entity that is subject to US taxation.  

. :)I am a novice investor currently investing in local Tax Lien Certificates in my area.I am seeking to revitalized this discussion because the most recent post prior to my general inquires are between 2-7 months old.Please feel free to reach and network with me my professional background is taxation coupled with QuickBooks.Anyone interested in jump starting the Tax Lien Certificate forum with new introductions, and information??

I begin investing in Tax Liens approximately two weeks ago.I felt the timing was right and since I had some disposable income, I jump head first.I am still relatively new to the area and invited a fellow business colleague to assist me with accessing some of the areas; well a partnership was born.Although, we are both novices in Tax Liens, I have a solid background in researching topics (mostly taxation) but I digress so I felt mildly comfortable with this sudden turn of events.Well in hindsight, my partner and I management style is vastly different; this is where the slight nuisances started to appear. 

So, you cannot be the handyperson or hardware store delivery clerk for your IRA's flip transaction.Flipping is also something that is considered a trade or business activity, and if carried on at a regular or repeated basis the gains from such transactions are subject to taxation known as UBTI.  

You can use some strategies (such as 1031 exchanges) to defer taxation, but otherwise the profit on each flip will be subject to taxes.

TAXATION AND FINANCE CHAPTER 45.

Tax Attorney's normally deal with more complex tax related issues than a CPA.I would expect a Tax Attorney to be dealing with issues such as1) International Tax Law / Transfer Pricing2) Drafting a Private Letter Ruling(PLR) with the IRS confirming that a tax position they will tax is blessed.3) Confirming or understanding recent tax law changes / updates4) Taxation rules for companies who operate over multiple states.Best of luck

What entities would I need to set up and what exposure would I have from regulatory and taxation stand-point?

@Michael RutkowskiWhether you should speak to a CPA or Attorney regarding questions you have on a 1031 depend on the specialty of the professional itself.Did the attorney you speak with specialize in taxation / real estate transfers? 

Being Canadian and not really planning on working in the US, not sure this would be worth it due to the cost to set this up and the continued double taxation.