A property investor from Hong Kong would like to acquire a large cash flow generating commercial property in California. Since he's a non-resident and has no plans to move here, he would like to limit his liabilities as an owner while minimizing his tax burden from the net profit generated from the rental income. He plans to pay in cash and have a resident partner/owner manage the property. The non-resident owner restriction with an S corp election seems to take that out of the running. Also, would he need to file a tax return in the US?