United States real property interest
Defined in 2 places of the United States Code.
Except as provided in subparagraph (B) or subsection (k), the term “United States real property interest” means—
(i) an interest in real property (including an interest in a mine, well, or other natural deposit) located in the United States or the Virgin Islands, and
(ii) any interest (other than an interest solely as a creditor) in any domestic corporation unless the taxpayer establishes (at such time and in such manner as the Secretary by regulations prescribes) that such corporation was at no time a United States real property holding corporation during the shorter of—
(I) the period after June 18, 1980, during which the taxpayer held such interest, or
(II) the 5-year period ending on the date of the disposition of such interest.
Source
- 2015–present26 U.S.C. § 897Internal Revenue Code · Disposition of investment in United States real property · for purposes of this section
Except as provided in subparagraph (B), the term “United States real property interest” means—
(i) an interest in real property (including an interest in a mine, well, or other natural deposit) located in the United States or the Virgin Islands, and
(ii) any interest (other than an interest solely as a creditor) in any domestic corporation unless the taxpayer establishes (at such time and in such manner as the Secretary by regulations prescribes) that such corporation was at no time a United States real property holding corporation during the shorter of—
(I) the period after June 18, 1980, during which the taxpayer held such interest, or
(II) the 5-year period ending on the date of the disposition of such interest.
Source
- 1994–201526 U.S.C. § 897Internal Revenue Code · Disposition of investment in United States real property · for purposes of this section
The term “United States real property interest” has the meaning given to such term by section 897(c).
Source
- 1994–present26 U.S.C. § 6039CInternal Revenue Code · Returns with respect to foreign persons holding direct investments in United States real property interests · for purposes of this section