real estate foreign exchange gain

(2) Real estate foreign exchange gain For purposes of this subsection, the term “real estate foreign exchange gain” means— (A) foreign currency gain (as defined in section 988(b)(1) ) which is attributable to— (i) any item of income or gain described in subsection (c)(3), (ii) the acquisition or ownership of obligations secured by mortgages on real property or on interests in real property (other than foreign currency gain attributable to any item of income or gain described in clause (i)), or (iii) becoming or being the obligor under obligations secured by mortgages on real property or on interests in real property (other than foreign currency gain attributable to any item of income or gain described in clause (i)), (B) section 987 gain attributable to a qualified business unit (as defined by section 989) of the real estate investment trust, but only if such qualified business unit meets the requirements under— (i) subsection (c)(3) for the taxable year, and (ii) subsection (c)(4)(A) at the close of each quarter that the real estate investment trust has directly or indirectly held the qualified business unit, and (C) any other foreign currency gain as determined by the Secretary.

Source

26 USC § 856(n)(2)


Scoping language

None identified. Default scope is assumed to be the entire title.
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