Different Tools, Same Problem
Housing affordability is a challenge across the developed world. Developed nations have responded with different combinations of policy tools - some restrict demand, some boost supply, most do both. No two countries take the same approach. But every country examined in this analysis acts on at least one of the five policy areas addressed by the Affordability and Immigration Act.
Japan, for instance, has no restrictions on foreign buyers or corporate ownership - yet keeps housing affordable through a national zoning system that makes construction fast, predictable, and abundant. Canada and New Zealand ban foreign buyers outright. Singapore uses prohibitive taxation. Switzerland has restricted foreign purchases since 1983. Each approach reflects different conditions and priorities.
The United States is the outlier not because it chose a different approach, but because it chose no approach. It has no federal restrictions on foreign buyers, no limits on corporate ownership of homes, no connection between immigration levels and housing capacity, and no federal role in housing construction or zoning.
| Country | Foreign Buyers | Corp. Ownership | Immigration | Visa Workers | Construction |
|---|---|---|---|---|---|
| Canada | Full ban (2023) | Provincial taxes | 25% cut (2024) | LMIA required | Federal housing fund |
| Australia | New builds only + 7-8% surcharge | Foreign investment review | Record high (counterexample) | TSS visa reforms | National Housing Accord |
| New Zealand | Full ban (2018) | Tax disincentives | Points-based system | Accredited employer system | National zoning override |
| Singapore | 60% stamp duty | 35% entity stamp duty | Managed system | Salary floors + quotas | Government builds 80% of housing |
| Japan | No restrictions | No restrictions | Selective expansion | Skills-based visa | National 12-zone system, 2-month permits |
| Switzerland | Lex Koller (1983) - cantonal quotas | Cantonal restrictions | Quota system | Labor market testing | Cantonal planning |
| United States | No federal restrictions | No federal restrictions | 1M+/year, no housing link | H-1B (exploited) | Local zoning, no federal role |
Sources: Government sources for each country, compiled by the authors.[1][2][3][4][5][6]
Key Finding
Every developed nation examined has at least one federal-level framework addressing housing affordability - whether through demand-side restrictions (foreign buyer bans, corporate ownership limits, immigration controls) or supply-side reform (national zoning systems, federal construction programs). The United States has no federal framework in any of the five areas.
Foreign Buyer Restrictions
Five of the six countries examined restrict foreign residential purchases through bans, prohibitive taxes, or regulatory review. The sixth - Japan - has no restrictions, but maintains affordable housing through supply-side policy (discussed below). The United States, like Japan, has no foreign buyer restrictions - but unlike Japan, has no alternative framework to keep housing affordable.
The approaches range from outright bans (Canada, New Zealand) to prohibitive taxation (Singapore) to regulatory gatekeeping (Australia, Switzerland). Each was implemented without the economic disruption critics predicted.
Foreign Buyer Restriction Severity by Country
Sources: CMHC, FIRB, NZ Overseas Investment Office, Singapore IRAS, Swiss FDJP, Japan MLIT[1][2][3][4][5][6]
| Country | Policy | Year | Mechanism | Result |
|---|---|---|---|---|
| Canada | Prohibition on the Purchase of Residential Property by Non-Canadians Act | 2023 | Outright ban on non-resident purchases; extended through 2027 | Foreign buyer activity dropped to near-zero in restricted markets |
| Australia | Foreign Investment Review Board (FIRB) | Ongoing (strengthened 2015) | Non-residents may only purchase new construction; 7-8% surcharges; annual vacancy fees; FIRB approval required | Foreign purchases of existing homes effectively eliminated |
| New Zealand | Overseas Investment Amendment Act | 2018 | Non-residents banned from purchasing existing residential property | Foreign buyer share dropped from 3.3% to under 0.5% within one year |
| Singapore | Additional Buyer Stamp Duty (ABSD) | 2011 (raised 2023) | 60% stamp duty for foreign buyers; 35% for entities; 20% for second-home citizens | Foreign buyer share dropped from 4.7% (2011) to 1.8% (2024) |
| Switzerland | Lex Koller (Federal Act on Acquisition of Real Estate by Persons Abroad) | 1983 | Non-residents restricted to designated tourist zones; cantonal quotas; strict size limits | Primary housing markets protected for 43 years; foreign ownership concentrated in resort areas |
Sources: Government legislation and regulatory bodies for each country[1][2][3][4][6]
Singapore: The Clearest Measurable Evidence
Singapore's Additional Buyer Stamp Duty (ABSD) provides the clearest before-and-after evidence. After raising the foreign buyer rate from 30% to 60% in April 2023, foreign purchases dropped from 4.7% of transactions to 1.8% - a 62% decline - while the broader market remained stable.[4] Singapore's economy continued to grow, foreign commercial investment was unaffected, and the policy achieved its stated goal of prioritizing housing for residents.
Corporate and Institutional Ownership
Restricting corporate ownership of residential property is an emerging policy area. While no country has implemented the comprehensive ban proposed by the Affordability and Immigration Act, several have enacted measures that make institutional residential acquisition significantly more expensive or subject to government review.
Japan again illustrates the supply-side alternative: it has no restrictions on corporate residential ownership, but corporate accumulation of housing is limited by the fact that housing is abundant and depreciates - reducing its attractiveness as a financial asset.[5] In the United States, where supply is artificially constrained, housing appreciates reliably - making it attractive to institutional investors in ways it is not in Japan.
As documented in our analysis of Wall Street's housing takeover, 32 institutional investors in the U.S. collectively own 450,000 single-family homes - a phenomenon that barely existed before 2011.[10]
| Country | Policy | Mechanism |
|---|---|---|
| Singapore | 35% entity stamp duty on residential purchases | Effectively prohibitive tax on corporate or entity residential purchases |
| Australia | Foreign investment review applies to corporate buyers; state-level surcharges | FIRB screens corporate acquisitions; additional stamp duties for foreign entities |
| Switzerland | Cantonal restrictions on institutional residential purchases | Cantons limit corporate acquisition of residential property; Lex Koller applies to foreign entities |
| South Korea | Corporate housing tax surcharges (2020) | Corporations pay up to 6% additional acquisition tax and higher holding taxes on residential property |
| Japan | No restrictions | No limits on corporate residential ownership; affordable housing maintained through abundant supply |
| United States | No federal restrictions | Institutional investors purchase single-family homes freely; 450,000+ homes held by 32 institutional investors |
Sources: FIRB, Singapore IRAS, Swiss FDJP, South Korea MOLIT, Japan MLIT[2][4][5][6][11]
Why Corporate Ownership Is a Problem in the U.S. but Not in Japan
Japan's lack of corporate ownership restrictions does not produce the same effects as the U.S. system because the underlying conditions are different. In Japan, housing is abundant - Tokyo alone permitted 140,000+ new units in 2023[5] - and homes depreciate over time, making them unattractive as speculative assets. In the United States, restricted supply creates reliable price appreciation, which is exactly what attracts institutional capital. The Act addresses this through both a corporate ownership ban (Policy 1) and supply-side reform (Policy 5) - removing the incentive and the restriction simultaneously.
Immigration and Housing Capacity
The relationship between immigration levels and housing affordability is observable across multiple countries. The most instructive evidence comes from a natural experiment: Canada and Australia pursued opposite immigration strategies in 2023-2024, with measurably different outcomes.
Canada vs. Australia: Opposite Strategies, Opposite Results
Sources: Statistics Canada, Australian Bureau of Statistics, Canada Mortgage and Housing Corporation, CoreLogic Australia[1][7]
Canada: Immigration Cuts, Rents Fell
In late 2024, Canada announced a 25% cut to immigration targets, explicitly citing housing affordability as a primary reason.[1] Within months, national rents fell 6.6% - the largest decline since tracking began. Vacancy rates in Toronto and Vancouver improved for the first time in years. Immigration Minister Marc Miller stated the cuts were necessary because “we lost the public's trust” on housing.[7]
Australia: Record Immigration, Rents Surged - Despite Building
Australia admitted a record 518,000 net migrants in 2022-2023.[2] Over the same period, national rents surged 47%, with some cities experiencing even steeper increases. The Reserve Bank of Australia explicitly linked record immigration to the rental crisis. Australia builds more housing per capita than the United States - yet could not keep pace with immigration-driven demand. This is the strongest evidence that construction alone cannot solve a supply-demand imbalance when demand grows unchecked.
The Affordability and Immigration Act proposes a 90% reduction in immigration for 10 years to allow U.S. housing supply to catch up with existing population - the same logic Canada has now adopted, though the Act goes further. Australia's experience shows why supply-side reform alone is insufficient when population growth outpaces construction capacity.
Visa Worker Program Safeguards
Every developed nation examined includes stronger worker protections in its temporary visa programs than the United States. Common safeguards include salary floors, labor market testing requirements (proving no domestic worker is available), and restrictions on staffing agency sponsorship.
Singapore: Employment Pass
Singapore's Employment Pass requires a minimum salary of SGD $5,600/month (approximately USD $4,200) - and significantly higher for experienced workers. Employers face foreign worker quotas limiting the proportion of non-citizens in their workforce. There is no equivalent of the H-1B staffing firm model.[4]
Australia: Temporary Skill Shortage (TSS) Visa
Australia's TSS visa requires employers to demonstrate labor market testing - evidence that no qualified Australian worker is available. Salary must meet market rates. The visa was reformed in 2024 to raise minimum salary thresholds and reduce exploitation by labor-hire firms.[2]
United States: H-1B
The H-1B program has no meaningful labor market testing. Sixty percent of H-1B positions are certified at Level 1 or Level 2 wages - below the median for the occupation and area.[12] The top employers are outsourcing firms, not innovative companies. The Act proposes ending H-1B and restoring the original H-1 visa with direct employment requirements, genuine specialty occupation standards, and no staffing agency sponsorship.
Housing Construction and Zoning Reform
The United States is unique among developed nations in having no federal role in housing construction or zoning. Over 30,000 local jurisdictions independently control permitting, zoning, and development approvals - resulting in wildly inconsistent timelines, costs, and outcomes.[9]
Japan offers the most compelling model - and the most important lesson in this analysis. Japan has no foreign buyer restrictions and no corporate ownership limits. Yet Tokyo is more affordable relative to income than most major U.S. cities. The reason is supply: Japan's national 12-zone system ensures that if a proposed building meets the zone requirements, it must be approved - no discretionary review, no public hearings for compliant projects.[8]
The Japan Question: If Supply Is Enough, Why Propose Demand-Side Reforms?
Japan demonstrates that abundant supply can keep housing affordable even without foreign buyer restrictions or corporate ownership limits. This raises a fair question: if the U.S. simply built enough housing, would the other four policies be unnecessary?
The answer is that the United States is not starting from Japan's position. Japan has maintained high construction rates for decades and has a declining population. The U.S. has a 3.8 million unit shortage,[9] adds over 1 million people annually through immigration alone, and faces deeply entrenched local opposition to new construction. Even with aggressive zoning reform, closing a 3.8 million unit gap while adding 1 million+ people per year would take decades.
Australia's experience confirms this: it builds more housing per capita than the United States but could not keep pace with record immigration.[2] The Act proposes both supply-side reform (Policy 5) and demand-side measures (Policies 1-4) because the U.S. cannot build its way out of the current crisis through construction alone - it is too far behind.
Average Residential Permitting Timelines by City
Sources: National housing agencies, municipal permitting data[8][9]
| Country | Approach | Permitting | Result |
|---|---|---|---|
| Japan | National 12-zone system; national building code overrides local rules | ~2 months average | Tokyo housing is more affordable relative to income than most major U.S. cities |
| Singapore | Government builds ~80% of housing (HDB); 99-year leasehold model | Government-managed | 90% homeownership rate; most affordable major Asian city for residents |
| New Zealand | Medium Density Residential Standards (2022); national override of local zoning | Streamlined for compliant builds | Building consents rose 12% in first year; highest per-capita construction in OECD |
| Canada | Housing Accelerator Fund; $4B federal funding tied to local zoning reform | Varies by municipality | 178 municipalities signed agreements; 750,000+ units enabled through zoning changes |
| Australia | National Housing Accord (2022); target 1.2M new homes over 5 years | State-level fast-track programs | Mixed results; immigration surge offset construction gains |
| United States | No federal zoning authority; 30,000+ local jurisdictions control permitting | 3-27 months depending on city | 3.8 million unit shortage; regulatory costs add 23.8% to home prices |
Sources: National housing agencies and statistical offices[1][2][3][5][8][9]
Japan: The Global Model for Housing Supply
Japan's national zoning system establishes 12 zones with clear, predictable rules. If a building meets the zone requirements, the permit is issued - typically within 2 months. There are no discretionary reviews for compliant projects. The result: despite population concentration in Tokyo, housing costs have remained stable relative to incomes for decades.[8] Japan demolished and rebuilt 87,000 homes in Tokyo in 2023 alone - the system treats housing as depreciating infrastructure, not as a speculative asset. This is why Japan does not need foreign buyer restrictions or corporate ownership limits: abundant supply removes the conditions that make those policies necessary elsewhere.
Comprehensive Policy Scorecard
The following scorecard summarizes how each country addresses the five policy areas of the Affordability and Immigration Act. No two countries take the same approach - but every country acts on at least one area at the national level. The United States is the only country with no federal framework in any category.
| Policy Area | CAN | AUS | NZ | SGP | JPN | CHE | USA |
|---|---|---|---|---|---|---|---|
| Foreign Buyer Restrictions | Full ban | Restricted + surcharges | Full ban | 60% tax | None | Restricted | None |
| Corporate Ownership Limits | Provincial taxes | FIRB review + surcharges | Tax disincentives | 35% entity tax | None | Cantonal limits | None |
| Immigration-Housing Link | Cut 25% citing housing | No link (counterexample) | Points-based | Managed system | Selective | Quota system | No link |
| Visa Worker Safeguards | LMIA labor test | TSS visa reforms | Employer accreditation | Salary floors + quotas | Skills-based visa | Labor market testing | H-1B (60% below median) |
| Federal Construction Role | $4B accelerator fund | National Accord | National zoning override | Govt builds 80% | National 12-zone system | Cantonal planning | None (local only) |
CAN = Canada, AUS = Australia, NZ = New Zealand, SGP = Singapore, JPN = Japan, CHE = Switzerland, USA = United States
What the Evidence Shows
The international record does not point to a single correct approach. It points to several findings:
Foreign buyer restrictions work where they are implemented. Switzerland has restricted foreign purchases for 43 years.[6] New Zealand's ban reduced foreign buyer share from 3.3% to under 0.5% within one year.[3] Singapore's 60% tax cut foreign transactions by 62%.[4] In no case did the predicted economic catastrophe materialize.
Abundant supply can substitute for demand-side restrictions - but only under specific conditions. Japan keeps housing affordable without foreign buyer bans or corporate ownership limits because its national zoning system ensures construction is fast, predictable, and abundant.[8] However, Japan also has a declining population - a condition the United States does not share. Countries with growing populations (Canada, Australia) have found that supply alone is insufficient.
Immigration levels and housing costs are directly linked. Canada's immigration cuts preceded a 6.6% rent decline.[7] Australia's record immigration preceded a 47% rent surge - despite active construction programs.[2] The direction of effect is consistent across countries and time periods.
Construction alone cannot offset unchecked demand growth. Australia built housing at higher per-capita rates than the United States but could not keep pace with record immigration.[2] This is the strongest evidence that effective policy requires addressing both sides of the supply-demand equation.
The United States is the only developed nation doing nothing at the federal level. Other countries use different tools - some restrict demand, some boost supply, most do both. The U.S. does neither. The Affordability and Immigration Act proposes a comprehensive approach because the U.S. problem is also comprehensive: a 3.8 million unit shortage,[9] 1 million+ immigrants per year,[7] 450,000 homes held by institutional investors,[10] and $56 billion in annual foreign purchases[13] - with no federal policy addressing any of it.
The Affordability and Immigration Act in International Context
The Act's five proposals - ending corporate ownership of single-family homes, reducing immigration for 10 years, restoring the H-1 visa, ending foreign residential purchases, and increasing housing construction through federal-local partnerships - draw on approaches already proven by developed nations. No single country implements all five. But every country addresses at least one of these problems at the national level. The United States addresses none. International experience demonstrates measurable results from each of these policy approaches. The United States remains one of the few developed nations without comparable federal-level restrictions.