United States real property interest

(B)The term “United States real property interest” does not include any interest in a corporation if— (i)as of the date of the disposition of such interest, such corporation did not hold any United States real property interests, (ii)all of the United States real property interests held by such corporation at any time during the shorter of the periods described in subparagraph (A)(ii)— (I)were disposed of in transactions in which the full amount of the gain (if any) was recognized, or (II)ceased to be United States real property interests by reason of the application of this subparagraph to 1 or more other corporations, and (iii)neither such corporation nor any predecessor of such corporation was a regulated investment company or a real estate investment trust at any time during the shorter of the periods described in subparagraph (A)(ii).

Source

26 USC § 897(c)(1)(B)


Scoping language

For purposes of this section
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