qualifying statement

(4) Transferee receives qualifying statement (A) In general This paragraph applies to the disposition if the transferee receives a qualifying statement at such time, in such manner, and subject to such terms and conditions as the Secretary may by regulations prescribe. (B) Qualifying statement For purposes of subparagraph (A), the term “qualifying statement” means a statement by the Secretary that— (i) the transferor either— (I) has reached agreement with the Secretary (or such agreement has been reached by the transferee) for the payment of any tax imposed by section 871(b)(1) or 882(a)(1) on any gain recognized by the transferor on the disposition of the United States real property interest, or (II) is exempt from any tax imposed by section 871(b)(1) or 882(a)(1) on any gain recognized by the transferor on the disposition of the United States real property interest, and (ii) the transferor or transferee has satisfied any transferor’s unsatisfied withholding liability or has provided adequate security to cover such liability.

Source

26 USC § 1445(b)(4)

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Scoping language

None identified, default scope is assumed to be the parent (subchapter A) of this section.

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