PE/Real Estate Investments in the US and Swiss Taxation

I've been dealing with the Swiss tax aspects of US-American cases for over 15 years. While it was very confidential at the beginning, it's becoming increasingly important now, particularly with investment opportunities in private equity or real estate (e.g. LandQuire®on US territory. But what tax rules apply in Switzerland for a Swiss tax resident investor?

Structuring: I have never seen a direct investment. Generally, it is made through local Partnership-type structures (rarely GP, more often LP) or LLCs.

Taxation 🇺🇸: Partnerships and C-Corp type LLCs (check the box) are fiscally transparent structures in the 🇺🇸

Taxation 🇨🇭
The taxation of partnerships doesn't raise too many questions, because either they are passive SPVs holding real estate, or they are on-site operations, and thus both elements are exempt in Switzerland – just for the rate.
⚠️ If the partnership is merely a passive SPV holding US securities, the tax authorities could treat the vehicle as a bank account – fully taxable in Switzerland.
The taxation of LLCs that are treated as C-corps has long been a subject of considerable discussion.
⏩ A number of tax specialists, including the undersigned, held the position that they were also transparent in Switzerland.
The cantonal and federal tax authorities considered them opaque (cf. Swiss Tax Conference – tax treatment of LLCs, 2011 document).
The question was clarified in a Federal Court ruling of 2015 (attached). The US LLC is tax-transparent in Switzerland.

Limits to fiscal transparency?
Transparency can be based on the CDI-USA. If this is the case, as the CDI-USA only covers «income» aspects, investment as wealth is not affected. Is wealth then opaque – and therefore taxable in Switzerland?
Transparency can be based on domestic law 🇨🇭. If this is the case, both income and assets are concerned. Transparency is total and the exemption applies to both income and assets.

Investing abroad, shiny brochures make it look cool, but it's better to know where you're standing fiscally.

Federal Tribunal, judgment 2C_894/2013, of 18 September 2015