Irc Section 897

Internal revenue code 26 usca section 897.

Irc section 897. 26 usc 897 disposition of investment in united states real property a general rule 1 treatment as effectively connected with united states trade or business. Individuals losing united states citizenship within the meaning of section 877 of the internal revenue code of 1986 on or after february 6 1995 and b long term residents of the united states with respect to whom an event described in former subparagraph a or b of section 877 e 1 of such code occurs on or after february 6 1995. Additionally under irc 897 g if money or property is exchanged for all or part of a foreign partner s interest in a partnership gain or loss is recognized to the extent attributable to a usrpi.

Non recognition may allow avoidance of irc 897. Finally 1 987 4 provides rules concerning the similar election under section 897 k for certain foreign corporations in the process of liquidation. A domestic corporation must withhold a tax equal to 15 of the fair market value of the property distributed to a foreign person if.

1954 to a related person within the meaning of section 453 f 1 of such code the basis of the interest in the hands of the person acquiring it shall be. In the case of any disposition after december 31 1979 of a united states real property interest as defined in section 897 c of the internal revenue code of 1986 formerly i r c. Section 1 897 3 sets forth rules pursuant to which certain foreign corporations may elect under section 897 i to be treated as domestic corporations for purposes of sections 897 and 6039c.

897 a 1 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. Irc 897 e 2 b ii authorizes the service to issue anti avoidance regulations. A corporation that is subject to the requirements of paragraph h 2 of this section or that voluntarily complies with the requirements of paragraph h 4 of this section must submit a supplemental statement to the internal revenue service if such corporation values goodwill or going concern value pursuant to 1 897 1 o 4 iii.