These Are Not Radical Ideas
Critics of the Affordability and Immigration Act of 2026 often characterize its proposals as extreme or unprecedented. The international record says otherwise. Restricting foreign home purchases, linking immigration to housing capacity, reforming visa worker programs, and enabling faster housing construction are mainstream policy approaches in peer democracies.
The following matrix compares six countries across all five policy areas addressed by the Act. The United States stands alone in having no federal framework for any of them.
| 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 | State-level fast-track |
| New Zealand | Full ban (2018) | Interest deductibility removed | Points-based system | Accredited employer system | Medium Density Standards |
| Singapore | 60% stamp duty | Entity stamp duty 35% | Managed system | Employment Pass salary floors | Government builds 80% of housing |
| Japan | No restrictions | No restrictions | Selective expansion | Specified Skilled Worker visa | National zoning (12 zones), 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
The United States is the only country examined with no federal framework for foreign buyer restrictions, corporate ownership limits, immigration-housing linkage, or federal construction policy. Every other peer democracy addresses at least three of these five policy areas at the national level.
Foreign Buyer Restrictions
Five of the six countries examined restrict foreign residential purchases. The approaches range from outright bans (Canada, New Zealand) to prohibitive taxation (Singapore) to regulatory gatekeeping (Australia, Switzerland). Only Japan has no statutory restrictions — and even Japan is considering reforms after a surge in foreign buying in resort areas like Niseko.[5]
The United States has no federal restrictions of any kind. Non-citizens, non-residents, and foreign entities may freely purchase residential property in any state, in any quantity, with no government review.
Foreign Buyer Restriction Severity by Country
Sources: CMHC, FIRB, NZ Overseas Investment Office, Singapore IRAS, Swiss FDJP[1][2][3][4][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 |
| Japan | No statutory restrictions | N/A | Registration required; no purchase ban; considering reforms after Hokkaido/Niseko foreign buying surge | Foreign buyers active in Tokyo and resort areas; domestic market largely affordable due to supply |
Sources: Government legislation and regulatory bodies for each country[1][2][3][4][5][6]
Singapore: The Clearest Evidence
Singapore's Additional Buyer Stamp Duty (ABSD) provides the clearest measurable 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.
The U.S. stands out for having no federal restrictions whatsoever. As documented in our analysis of Wall Street's housing takeover, 32 institutional investors collectively own 450,000 single-family homes — a phenomenon that barely existed before 2011.[10]
| Country | Policy | Mechanism |
|---|---|---|
| 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 |
| Singapore | 35% entity stamp duty on residential purchases | Effectively prohibitive tax on corporate or entity residential purchases |
| South Korea | Corporate housing tax surcharges (2020) | Corporations pay up to 6% additional acquisition tax and higher holding taxes on residential property |
| 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[2][4][6][11]
The Act's Approach vs. International Practice
The Affordability and Immigration Act proposes an outright prohibition on corporate ownership of single-family homes, with a 2-year divestment period. This goes further than any current international policy. However, the principle — that residential housing should serve residents, not financial portfolios — is consistent with the direction of policy in peer democracies. Singapore's 35% entity stamp duty is effectively prohibitive.[4] South Korea's corporate housing surcharges were explicitly designed to discourage institutional speculation.[11]
Immigration and Housing Capacity
The relationship between immigration levels and housing affordability is observable across multiple countries. But 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: A Natural Experiment in Immigration and Rents
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
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. Despite building more housing per capita than the United States, Australia could not keep pace with immigration-driven demand.
The contrast is instructive. Canada reduced immigration and rents fell. Australia increased immigration and rents surged — even with active construction programs. The lesson: construction alone cannot solve a supply-demand imbalance if demand grows faster than supply. 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.
Visa Worker Program Safeguards
Most peer democracies include stronger worker protections in their 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. Its 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. The result: Tokyo is more affordable relative to income than most major U.S. cities, despite being one of the world's largest metropolitan areas.[8]
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 infrastructure, not as a speculative asset.
Comprehensive Policy Scorecard
The following scorecard summarizes how each country addresses the five policy areas of the Affordability and Immigration Act. The pattern is clear: peer democracies act on multiple fronts simultaneously. The United States acts on none.
| 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 Housing 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 provides several clear findings:
Foreign buyer restrictions work and are sustainable. 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.
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.[2] The direction of effect is consistent across countries and time periods.
National zoning frameworks enable faster, cheaper construction. Japan's 12-zone system produces permits in 2 months.[8] New Zealand's national Medium Density Standards increased building consents 12% in the first year.[3] Fragmented local control — as practiced in the U.S. — produces the slowest and most expensive permitting in the developed world.
Construction alone is not sufficient if demand continues to grow. Australia built housing at higher per-capita rates than the United States but could not keep pace with record immigration.[2] Effective policy requires addressing both sides of the supply-demand equation — as the Affordability and Immigration Act proposes.
The United States is the only peer democracy with no comprehensive framework. Every country examined acts on at least three of the five policy areas. The U.S. acts on none at the federal level. The Affordability and Immigration Act would bring the United States in line with international practice.
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 — are not without precedent. They draw on proven approaches from peer democracies, adapted to U.S. conditions. The question is not whether these policies can work. The evidence shows they do. The question is whether the United States will adopt them.