United States real property interest

(A)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, during which the taxpayer held such interest, or (II)the 5-year period ending on the date of the disposition of such interest.

Source

26 USC § 897(c)(1)(A)


Scoping language

For purposes of this section
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