Korea, Australia, Germany, and the Netherlands all share one premise: they are countries that can act alone.
Korea is a unitary state; chaebol-dominated real estate speculation is a domestic issue. Australia is a federation; negative gearing and superannuation funds are domestic issues. Germany is the EU core; the debt brake and energy transition are domestic issues. The Netherlands is the EU financial hub; the tax avoidance architecture is a domestic issue.
They all have external coordination needs, but none of them has a structural dependency that makes unilateral action impossible.
North America is different.
The United States and Canada share the world's longest border, the same capital market logic, and the same real estate speculation structure. Capital flows freely between the two countries, but policy remains separated.
If Canada unilaterally restricts foreign buyers, US capital will withdraw, Asian capital will redirect, and Canada will bear all the costs. If the US unilaterally restricts institutional investors, US capital will flow to Canada, and Canada will bear all the consequences.
The core of the North America proposal is not "what each country does" — it is "how the two countries act together."
This is a regional design problem, not a拼接 of two national proposals.
1.1 Canada: A Capital Haven, Not an Independent Real Estate Market
The drivers of Canada's real estate market are not "foreign buyers" in the vague sense. They are the interweaving of three capital flows.
First, US capital. US institutional investors, REITs, and private equity funds invest heavily in Canadian real estate. What they buy is not "Canadian real estate" — they buy "North American real estate," and Canada is just part of that market. Blackstone, Brookfield, and other US private equity funds hold large amounts of residential and commercial property in major Canadian cities.
Second, Asian capital. Capital from China, Hong Kong, and the Middle East enters the North American market through Vancouver and Toronto. They choose Canada not because Canada is better, but because Canada is the gateway to the United States. Canada's lenient immigration policy, stable legal system, and close economic ties with the US make it the first stop for Asian capital landing in North America.
Third, Canada's own pension funds. CPPIB manages over CAD 500 billion, making it one of Canada's largest institutional investors. Its real estate portfolio turns Canadian housing into a speculative vehicle. CDPQ, PSP Investments, and other provincial pension funds do the same.
The interweaving of these three capital flows makes it impossible for the Canadian government to act alone. If Canada restricts foreign buyers, US capital will withdraw. If Canada restricts pension funds, CPPIB will lose returns. If Canada does nothing, the housing crisis for young people will continue to worsen.
Canada is not an independent real estate market. It is an extension of the North American capital market.
1.2 The United States: Capital Exporter, Also Housing Crisis Exporter
The US is the primary source of capital for Canadian real estate. But the US's own housing crisis is more severe than Canada's.
The US problem is not "foreign capital" — it is "domestic capital." After the 2008 financial crisis, US institutional investors, REITs, and private equity funds bought up foreclosed properties en masse, turning housing into a financial product. Blackstone became the largest landlord in the US. Single-family rental companies like Invitation Homes and American Homes 4 Rent hold large amounts of housing in the US South and West.
The US housing crisis is being exported to Canada. When US capital saturates the domestic market, it flows to Canada. When Canada also saturates, it flows to Mexico, the UK, Australia.
This is a chain reaction. And Canada is the first stop.
1.3 The Common Trap: Capital Flows Freely, Policy Remains Separate
The greatest structural flaw in North America is not a problem of either country — it is the institutional gap between the two.
The US and Canada share a capital market, but not a regulatory framework. They share real estate speculation logic, but not tax coordination. They share Indigenous land justice issues, but not resolution mechanisms. They share the pressure of collapsing healthcare systems, but not the fiscal foundation.
Capital arbitrages between the two countries, and neither government can stop it.
This is not a "federalism problem" — it is a "bilateral institutional gap problem."
The core of the North America proposal is to fill this gap.
Before proposing an alternative, it is necessary to honestly examine the policy directions currently being pursued by the US and Canada. These policies are not without intent, but their design contains three common structural weaknesses.
2.1 The US 21st Century ROAD to Housing Act: Limiting Increment, Not Addressing Stock
In July 2026, the US passed its most significant federal housing bill in nearly three decades. Its core provisions include: prohibiting institutional investors holding more than 350 single-family homes from further purchases, streamlining environmental review, expanding manufactured housing financing, and establishing federal zoning reform incentives for the first time.
However, this approach contains a key structural flaw: it only limits "incremental acquisitions," not "existing holdings."
The bill explicitly states that large institutional investors may not purchase additional single-family homes, but existing portfolios are unaffected. This means that Blackstone, Invitation Homes, American Homes 4 Rent, and others already hold hundreds of thousands of homes, and those homes will not enter the market because of this bill. They can continue to act as landlords collecting rent, just not buy more.
This is a "stop the bleeding" plan, not a "clean the wound" plan. It prevents institutional capital from expanding further, but does not address the housing stock already occupied by institutional capital.
More critically, the bill's implementation depends on the speed of federal agency execution. The bill itself is "authorizing" in nature — specific implementation rules, enforcement mechanisms, and penalties for violators all require subsequent administrative action. President Trump initially refused to sign the bill; it only took effect automatically because the constitutional 10-day period expired. This "passive enactment" means the administration may lack the political will to push for enforcement.
2.2 Canada's Build Canada Homes: A Flagship Program with Zero Deliveries
Canada's problem is more direct.
The federal government's flagship housing agency, Build Canada Homes, was confirmed by the housing minister himself in March 2026: zero homes completed. This CAD 13 billion program was described as "in launch mode," with 1,000 homes "in the pipeline."
The Parliamentary Budget Officer (PBO) projects the program will produce 26,000 homes over five years, filling only 3.7% of the housing gap identified by the PBO. Canada needs 430,000 to 480,000 homes per year to restore affordability.
This is not a speed-of-execution problem. This is a magnitude-of-design-versus-need problem.
The opposition Conservative Party directly called Build Canada Homes an "unnecessary agency," criticizing it for "just adding another layer of bureaucracy to housing construction." NDP housing critic Jenny Kwan pointed out that the bill does not define the core term "affordable housing," while granting BCH "extraordinarily broad powers" with "limited parliamentary oversight."
The specific measures the Canadian government has actually rolled out show the same structural weaknesses:
First-time homebuyer GST rebate: Of 7,500 applications nationwide, only 150 were approved, with a rejection rate 4 times the approval rate. The government budgeted CAD 68.2 million for administration, but as of June 19, only CAD 3.58 million in rebates had been disbursed.
Purchasing unsold condos: The federal and BC governments jointly announced the purchase of 2,200 unsold condos, but the policy was criticized as "bailing out large developers." Conservative leader Pierre Poilievre called it "subsidizing people with yachts to people without yachts." The government's acquisitions are concentrated in lower-priced markets like the Fraser Valley, Okanagan, and Vancouver Island, with high-end condos in Greater Vancouver excluded.
Modular housing strategy: The Canadian government is investing CAD 25 billion to promote prefabricated housing, targeting 500,000 units per year. But Deloitte's industry research shows modular construction has less than 5% market share in Canada. Sweden's experience shows that achieving scale profitability requires 20 years of uninterrupted capacity investment. Canada previously pushed similar programs after WWII and in the 1970s, both ultimately failed when demand fell.
2.3 The Common Structural Weakness: Unilateral Action Cannot Solve Cross-Border Capital Arbitrage
The policy directions of both the US and Canada share a common blind spot: they are both trying to solve "cross-border capital flows" with "domestic supply-side reform."
The US 21st Century ROAD to Housing Act restricts institutional investors within the United States. But the bill does not address a key fact: US capital can flow to Canada. When US institutional investors are restricted domestically, they will turn to the Canadian market. Canada's lenient regulatory environment, close economic ties with the US, and lack of beneficial ownership registry make it a natural extension market for US capital.
Canada's Build Canada Homes aims to increase Canada's domestic housing supply. But Canada does not address a key fact: Asian and US capital are driving up Canadian housing prices. Canada is itself a capital channel. If Canada establishes strict beneficial ownership registry, Asian capital will go directly to the US, and Canada will lose its status as a transit hub.
Both countries' policies are "treating symptoms," not "treating the root cause." The US bill limits incremental acquisitions by US institutional investors, but does not prevent them from turning to Canada. Canada's program increases Canadian housing supply, but does not stop foreign capital from continuing to drive up prices.
3.1 First Pillar: North American Beneficial Ownership Registry
Foreign buyers' taxes and vacancy taxes fail not because the rates are too low, but because they cannot penetrate trust structures, corporate structures, or indirect holding through student visas. Canada has a foreign buyers' tax; the US has FIRPTA. But neither can penetrate the identity of the actual holder.
Measures:
- The US and Canada jointly establish a "North American Beneficial Ownership Registry": all entities (individuals, companies, trusts, funds, partnerships) purchasing real estate in North America must register the actual holder.
- Registration information includes: identity of the actual holder, nationality, tax residency, ultimate source of funds, and ultimate beneficial percentage.
- Entities that fail to register or file false registrations are subject to fines of 30% to 50% of property value and frozen real estate transaction eligibility.
- The registry is jointly maintained by the US and Canada, and opened to other willing countries.
- The two countries jointly establish a "North American Beneficial Ownership Registry Committee," composed of finance ministries, central banks, and independent audit institutions, to oversee the registry's operation.
Execution body — who moves first: The US moves first, because the 2026 housing bill has already opened the legislative window. Congress can add a beneficial ownership registry provision to the bill's implementation rules. Canada follows within 12 months, using the "national security review" framework already in place for foreign investment.
Mathematical logic: If the US and Canada each establish their own registry, capital will arbitrage between the two. If they establish a joint registry, the arbitrage space disappears. This is the only way to penetrate the North American capital market.
3.2 Second Pillar: North American Capital Flow Stabilization Fund
Measures:
- The US Federal Reserve and the Bank of Canada jointly establish a "North American Capital Flow Stabilization Fund."
- When foreign capital massively exits the North American real estate market, the stabilization fund absorbs the shock to prevent systemic collapse.
- The fund's resources come from fines from the North American Beneficial Ownership Registry and a portion of both countries' land value taxes.
- The fund's operations are jointly supervised by the US and Canada and disclosed to the public.
- The fund's management committee is composed of the US and Canadian finance ministers, central bank governors, and independent economists.
Execution body — who moves first: The Federal Reserve and the Bank of Canada jointly submit a proposal to the two finance ministries. This is the existing channel — the two central banks already coordinate on monetary policy and financial stability through the G7 and bilateral channels. Real estate capital regulation is an extension of financial stability, not a new mandate.
Mathematical logic: Capital flight is faster than any single country's policy response. Only a bilateral stabilization fund can absorb the shock in real time.
3.3 Third Pillar: The Moral Turn of Pension Funds
Measures:
- The US and Canada jointly set a "public pension fund real estate investment cap": any public pension fund's speculative real estate holdings may not exceed 10% of its total assets.
- Tax incentives are provided for investments in public housing, long-term care facilities, and infrastructure.
- CPPIB, CDPQ, PSP Investments, CalPERS, CalSTRS, and other public pension funds are required to publicly disclose the social impact of their real estate investments annually.
- A "North American Public Housing Investment Fund" is established to encourage pension fund participation, with tax incentives jointly provided by the US and Canada.
- Pension funds that violate the investment cap are subject to fines and lose their tax incentive eligibility.
Execution body — who moves first: The boards of CPPIB and CalPERS move first. Both are independent institutions with fiduciary duties; both have already begun discussing "social return" in their investment frameworks. Once the two largest funds adopt the 10% cap, other funds will follow, and the two governments will then codify the standard in tax law.
Mathematical logic: The goal of public pension funds is to provide stable returns for retirees. But if real estate speculation drives up housing prices, young people cannot afford homes, and future retirees (today's young) will be unable to accumulate wealth. Pension fund investment in public housing is not "sacrificing returns" — it is "protecting future retirees."
3.4 Fourth Pillar: Indigenous Land Justice
Measures:
- The US and Canada jointly establish a "North American Indigenous Land Value Fund": higher land value taxes are levied on resource development on Indigenous traditional lands, with proceeds returned to Indigenous communities.
- Long-term structural support is provided for housing, healthcare, education, and employment in Indigenous communities.
- The two countries jointly recognize the cross-border nature of Indigenous land rights.
- A "North American Indigenous Land Rights Committee" is established, composed of Indigenous representatives, government representatives, and independent legal experts, to coordinate cross-border Indigenous land rights issues.
- Developers on Indigenous traditional lands are required to sign "Benefit Sharing Agreements" with Indigenous communities.
Execution body — who moves first: The Assembly of First Nations (Canada) and the National Congress of American Indians (US) jointly sign a bilateral protocol, then present it to both governments. Indigenous nations are sovereign entities; their bilateral agreements do not require government permission to be signed — only to be implemented.
Mathematical logic: Resource development on Indigenous traditional lands generates enormous land value. This value should return to Indigenous communities, not flow to transnational corporations.
3.5 Fifth Pillar: The Fiscal Foundation of Healthcare
Measures:
- The US and Canada jointly establish a "North American Healthcare Fiscal Fund": with land value tax as the fiscal source, dedicated to the public healthcare system.
- Higher land value taxes are levied on land value increments around healthcare facilities.
- Fund revenues are used to lower drug prices, expand general practitioner training, and build public healthcare infrastructure.
- A "North American Healthcare Mutual Recognition Mechanism" is established for cross-border healthcare services, allowing patients from both countries to receive care in the other.
- A "North American Drug Price Negotiation Mechanism" is established, with both countries jointly negotiating with pharmaceutical companies to lower drug prices.
Execution body — who moves first: The two health ministers move first, through the existing Canada-US Regulatory Cooperation Council. Drug price negotiation is already a shared interest — the US Medicare negotiation program and Canada's Patented Medicine Prices Review Board have overlapping mandates. The bilateral mechanism extends existing practice, not invents new authority.
Mathematical logic: The collapse of healthcare systems is not a "healthcare problem" — it is a "fiscal problem." Land value tax is the only tax base that cannot be escaped by transnational capital.
4.1 Supporters
- Younger generation (US and Canada): housing crisis and intergenerational injustice make them support beneficial ownership registry, pension fund redirection, and public capture of land value.
- Indigenous communities (US and Canada): the Indigenous Land Value Fund gives them a chance to recover land value stripped by transnational corporations.
- Healthcare workers and patients (US and Canada): the Healthcare Fiscal Fund gives them a chance to improve the healthcare system.
- SMEs (US and Canada): beneficial ownership registry combats transnational corporate tax avoidance, giving them a fair competitive environment.
- Trade unions (US and Canada): land value tax provides funding for healthcare and pensions, aligning with union interests.
4.2 Opponents
- US private equity and REITs: beneficial ownership registry and pension fund caps directly touch their interests.
- Canadian real estate interest groups: land value tax directly touches them.
- Transnational corporations: beneficial ownership registry undermines their tax avoidance structures.
- Some pension fund trustees: the moral turn of pension funds may affect returns in the short term.
- Right-wing parties (US and Canada): will portray the reform as a "socialist conspiracy" or "surrender to the Global South."
4.3 Political Strategy
- Divide the opponents: US private equity and Canadian real estate interest groups have different interests. Do not bind them together.
- Expand the supporters: younger generation, Indigenous communities, healthcare workers, SMEs, and trade unions can form a cross-border coalition.
- Shift the narrative: not "restricting capital freedom," but "making capital serve public purposes."
- Give opponents a way out: transition funds and tax incentives for private equity and real estate interest groups, encouraging them to shift from speculation to public investment.
A proposal does not implement itself. It needs a driver. North America currently has no such driver. This is not a failure of the proposal. It is a fact of the political structure.
But the absence of a driver does not mean permanent inaction. It means the proposal waits for a trigger. Four indicators will determine when the waiting ends.
Trigger One: US institutional investor ownership share
If institutional investors hold more than 5% of the single-family housing stock in the top 50 US metropolitan areas, the "increment limit only" approach of the 2026 housing bill becomes visibly insufficient. At that point, the North American Beneficial Ownership Registry and the pension fund cap become politically unavoidable.
Current baseline: Approximately 3-4% in most markets, higher in the Sun Belt. The threshold is within reach within 5-8 years.
Trigger Two: Canadian Medicare wait times
If the median wait time from GP referral to specialist treatment exceeds 40 weeks, the fiscal foundation of the healthcare system becomes the dominant political issue. The North American Healthcare Fiscal Fund becomes the only credible structural response.
Current baseline: Approximately 30 weeks (Fraser Institute, 2025). The threshold is within reach within 3-5 years if current trends continue.
Trigger Three: Youth homeownership rates
If the homeownership rate for the 25-34 age cohort falls below 35% in both the US and Canada, intergenerational inequality becomes the dominant electoral issue. At that point, the pension fund moral turn and the Indigenous Land Value Fund become politically viable.
Current baseline: Approximately 38-40% in both countries. The threshold is within reach within 5-7 years.
Trigger Four: Federal fiscal deficit
If either country's federal deficit exceeds 8% of GDP in a non-recession year, the structural fiscal gap becomes undeniable. At that point, land value tax as the fiscal foundation becomes a practical necessity, not an ideological choice.
Current baseline: US at approximately 6-7%, Canada at approximately 2-3%. The threshold for the US is closer than for Canada.
When any two of these four triggers are met, this proposal moves from reserve to active. When three are met, the political cost of inaction exceeds the political cost of action.
It will not be adopted within five years. But it needs to be there when the crisis arrives.
The US housing crisis is worsening. The share of single-family homes held by institutional investors has risen over the past decade. Youth homeownership rates have continued to fall. The 2026 housing bill only limits increment, not stock.
Canada's healthcare system is collapsing. Medicare wait times continue to lengthen. Specialist shortages and fiscal pressure continue to rise. Build Canada Homes completed zero homes. The GST rebate rejection rate is four times the approval rate.
Population aging in both countries is accelerating. Healthcare and pension spending continue to rise, while the tax base continues to hollow out.
These pressures will approach critical mass within the next decade. At that point, this proposal will be the only ready-made, executable, bilaterally coordinated mathematical framework.
Its implementation does not depend on how well it is written. It depends on how fast the crisis arrives.
This proposal is not written for the present. It is written so that when the crisis arrives, someone can immediately take it out and use it.
Conclusion
The problems of the United States and Canada are not unique. They are the most acute manifestation of the "Shared Delusion" in the North American capital market. But the problem for both countries is not "not knowing how to do it." It is "not daring to do it alone."
An effective North America proposal cannot only say "what should be done." It must say "how to make this possible within the political structures of both countries."
This is not ideology. This is political design.