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26 U.S.C. § 6039C — Returns with respect to foreign persons holding direct investments in United States real property interests
Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** To the extent provided in regulations, any foreign person holding direct investments in United States real property interests for the calendar year shall make a return setting forth—
(1) the name and address of such person,
(2) a description of all United States real property interests held by such person at any time during the calendar year, and
(3) such other information as the Secretary may by regulations prescribe.
**(b) Definition of foreign persons holding direct investments in United States real property interests** For purposes of this section, a foreign person shall be treated as holding direct investments in United States real property interests during any calendar year if—
(1) such person did not engage in a trade or business in the United States at any time during such calendar year, and
(2) the fair market value of the United States real property interests held directly by such person at any time during such year equals or exceeds $50,000.
**(c) Definitions and special rules** For purposes of this section—
(1) **United States real property interest** — The term “United States real property interest” has the meaning given to such term by section 897(c).
(2) **Foreign person** — The term “foreign person” means any person who is not a United States person.
(3) **Attribution of ownership** — For purposes of subsection (b)(2)—
(A) *Interests held by partnerships, etc.* — United States real property interests held by a partnership, trust, or estate shall be treated as owned proportionately by its partners or beneficiaries.
(B) *Interests held by family members* — United States real property interests held by the spouse or any minor child of an individual shall be treated as owned by such individual.
(4) **Time and manner of f
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Source file: Laws/federal/codes/united-states-code/title-26/section-6039c-returns-with-respect-to-foreign-persons-holding-direct-investments-in-un--be5e387f4b.md
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Source location: Title 26, Chapter 61, § 6039C; chapter-061-information-and-returns.md
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**(a) General rule** To the extent provided in regulations, any foreign person holding direct investments in United States real property interests for the calendar year shall make a return setting forth—
(1) the name and address of such person,
(2) a description of all United States real property interests held by such person at any time during the calendar year, and
(3) such other information as the Secretary may by regulations prescribe.
**(b) Definition of foreign persons holding direct investments in United States real property interests** For purposes of this section, a foreign person shall be treated as holding direct investments in United States real property interests during any calendar year if—
(1) such person did not engage in a trade or business in the United States at any time during such calendar year, and
(2) the fair market value of the United States real property interests held directly by such person at any time during such year equals or exceeds $50,000.
**(c) Definitions and special rules** For purposes of this section—
(1) **United States real property interest** — The term “United States real property interest” has the meaning given to such term by section 897(c).
(2) **Foreign person** — The term “foreign person” means any person who is not a United States person.
(3) **Attribution of ownership** — For purposes of subsection (b)(2)—
(A) *Interests held by partnerships, etc.* — United States real property interests held by a partnership, trust, or estate shall be treated as owned proportionately by its partners or beneficiaries.
(B) *Interests held by family members* — United States real property interests held by the spouse or any minor child of an individual shall be treated as owned by such individual.
(4) **Time and manner of filing return** — All returns required to be made under this section shall be made at such time and in such manner as the Secretary shall by regulations prescribe.
**(d) Special rule for United States interest and Virgin Islands interest** A nonresident alien individual or foreign corporation subject to tax under section 897(a) (and any person required to withhold tax under section 1445) shall pay any tax and file any return required by this title—
(1) to the United States, in the case of any interest in real property located in the United States and an interest (other than an interest solely as a creditor) in a domestic corporation (with respect to the United States) described in section 897(c)(1)(A)(ii), and
(2) to the Virgin Islands, in the case of any interest in real property located in the Virgin Islands and an interest (other than an interest solely as a creditor) in a domestic corporation (with respect to the Virgin Islands) described in section 897(c)(1)(A)(ii).
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Energy credit**
(1) **In general** — For purposes of section 46, except as provided in paragraphs (1)(B), (2)(B), and (3)(B) of subsection (c), the energy credit for any taxable year is the energy percentage of the basis of each energy property placed in service during such taxable year.
(2) **Energy percentage**
(A) *In general* — Except as provided in paragraphs (6) and (7), the energy percentage is—
(i) 6 percent in the case of—
(I) qualified fuel cell property,
(II) energy property described in clause (i) or (iii) of paragraph (3)(A) but only with respect to property the construction of which begins before January 1, 2025,
(III) energy property described in paragraph (3)(A)(ii),
(IV) qualified small wind energy property,
(V) waste energy recovery property,
(VI) energy storage technology,
(VII) qualified biogas property,
(VIII) microgrid controllers, and
(IX) energy property described in clauses (v) and (vii) of paragraph (3)(A), and
(ii) in the case of any energy property to which clause (i) does not apply, 0 percent.
(B) *Coordination with rehabilitation credit* — The energy percentage shall not apply to that portion of the basis of any property which is attributable to qualified rehabilitation expenditures.
(C) *Nonapplication of increases to energy percentage* — For purposes of energy property described in subparagraph (A)(ii), the energy percentage applicable to such property pursuant to such subparagraph shall not be increased or otherwise adjusted by any provision of this section.
(3) **Energy property** — For purposes of this subpart, the term “energy property” means any property—
(A) which is—
(i) equipment which uses solar energy to generate electricity, to he
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule**
(1) **Treatment as effectively connected with United States trade or business** — For purposes of this title, gain or loss of a nonresident alien individual or a foreign corporation from the disposition of a United States real property interest shall be taken into account—
(A) in the case of a nonresident alien individual, under section 871(b)(1), or
(B) in the case of a foreign corporation, under section 882(a)(1),
as if the taxpayer were engaged in a trade or business within the United States during the taxable year and as if such gain or loss were effectively connected with such trade or business.
(2) **Minimum tax on nonresident alien individuals**
(A) *In general* — In the case of any nonresident alien individual, the taxable excess for purposes of section 55(b)(1) shall not be less than the lesser of—
(i) the individual’s alternative minimum taxable income (as defined in section 55(b)(1)(D)) for the taxable year, or
(ii) the individual’s net United States real property gain for the taxable year.
(B) *Net United States real property gain* — For purposes of subparagraph (A), the term “net United States real property gain” means the excess of—
(i) the aggregate of the gains for the taxable year from dispositions of United States real property interests, over
(ii) the aggregate of the losses for the taxable year from dispositions of such interests.
**(b) Limitation on losses of individuals** In the case of an individual, a loss shall be taken into account under subsection (a) only to the extent such loss would be taken into account under section 165(c) (determined without regard to subsection (a) of this section).
**(c) United States real property interest** For purposes of this section—
(1) **United States r
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Annual report on foreign direct investment in United States** Not later than 6 months after November 7, 1990, and not later than the end of each 1-year period occurring thereafter, the Secretary of Commerce shall submit to the Committee on Energy and Commerce, the Committee on Ways and Means, and the Committee on Foreign Affairs of the House of Representatives, to the Committee on Commerce, Science, and Transportation of the Senate, and to the Joint Economic Committee of the Congress a report on the role and significance of foreign direct investment in the United States. Such report shall address the history, scope, trends, market concentrations, and effects on the United States economy of such investment. In addition, the Secretary of Commerce shall, if requested by any such committee, appear before that committee to provide testimony with respect to any report under this subsection.
**(b) Sources of data** In preparing each report under subsection (a), the Secretary of Commerce, or the Secretary’s designees, shall consider information collected by—
(1) the Bureau of Economic Analysis under the International Investment and Trade in Services Survey Act ([22 U.S.C. 3101](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title22-section3101&num=0&edition=prelim) and following);
(2) the Bureau of the Census on industry, manufacturing, research and development, and trade, under title 13;
(3) the Bureau of Labor Statistics pertaining to information collected under the International Investment and Trade in Services Survey Act, but only to the extent that such information is in a form that cannot be associated with, or otherwise identify, directly or indirectly, a person, including any enterprise or establishment;
(4) the Secretary of Commerce or the Secr
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Federal law — U.S. Code and appendices · legal_authorities
Page 3344
TITLE 26—INTERNAL REVENUE CODE
[§ 6039A
1998—Subsec. (a)(1). Pub. L. 105–206 inserted ‘‘to any
person’’ after ‘‘transfers’’.
1990—Subsec.
(a)(1),
(2).
Pub.
L.
101–508,
§ 11801(c)(9)(J)(i), added pars. (1) and (2) and struck out
former pars. (1) and (2) which read as follows:
‘‘(1) which in any calendar year transfers a share of
stock to any person pursuant to such person’s exercise
of a qualified stock option, an incentive stock option,
or a restricted stock option, or
‘‘(2) which in any calendar year records (or has by its
agent recorded) a transfer of the legal title of a share
of stock—
‘‘(A) acquired by the transfer or pursuant to his ex-
ercise of an option described in section 423(c) (relat-
ing to special rule where option price is between 85
percent and 100 percent of value of stock), or
‘‘(B) acquired by the transferor pursuant to his ex-
ercise of a restricted stock option described in sec-
tion 424(c)(1) (relating to options under which option
price is between 85 percent and 95 percent of value of
stock),’’.
Subsec. (b)(1). Pub. L. 101–508, § 11801(c)(9)(J)(ii), sub-
stituted ‘‘an incentive stock option or an’’ for ‘‘a quali-
fied stock option, incentive stock option, a restricted
stock option, or an’’.
Subsec. (c). Pub. L. 101–508, § 11801(c)(9)(J)(iii), amend-
ed subsec. (c) generally, striking out references for defi-
nitions of ‘‘qualified stock option’’ and ‘‘restricted
stock option’’.
1981—Subsec. (a)(1). Pub. L. 97–34, § 251(b)(5)(A), in-
serted ‘‘, an incentive stock option,’’ after ‘‘qualified
stock option’’.
Subsec. (b)(1). Pub. L. 97–34, § 251(b)(5)(B), inserted
‘‘incentive stock option,’’ after ‘‘qualified stock op-
tion,’’.
Subsec. (c)(4). Pub. L. 97–34, § 251(b)(5)(C), added par.
(4).
1979—Subsec. (a). P
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