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Important
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For information call now:
(347) 989-4566
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Additional information
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Internal Revenue Service
Austin Service Center
ITIN Operation
P.O. Box 149342
Austin, TX 78714-9342
IN
1-800-829-1040
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U.S. real property holding corporation
A corporation is a U.S. real property holding corporation if the fair market
value of the corporation�s U.S. real property interests are at least 50% of the
total fair market value of:
� The corporation�s U.S. real property interests, plus
� The corporation�s interests in real property located outside the United
States, plus
� The corporation�s other assets that are used in, or held for use in, a trade
or business.
Gain or loss on the sale of the stock in any domestic corporation is taxed as if
you are engaged in a U.S. trade or business unless you establish that the
corporation is not a U.S. real property holding corporation.
A U.S. real property interest does not include a class of stock of a corporation
that is regularly traded on an established securities market, unless you hold
more than 5% of the fair market value of that class of stock. An interest in a
foreign corporation owning U.S. real property generally is not a U.S. real
property interest unless the corporation chooses to be treated as a domestic
corporation.
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