Treasury Regulations (26 C.F.R.)
26 CFR § 1.897-8T
Status as a U.S. real property holding corporation as a condition for electing section 897(i) pursuant to § 1.897-3 (temporary).
Official textecfr.govlast amended
# (a) Purpose and scope.
This section provides a temporary regulation that if and when adopted as a final regulation, will be added to paragraph (b) of § 1.897-3. Paragraph (b) of this section would then appear as paragraph (b)(4) of § 1.897-3.
# (b) General conditions.
The foreign corporation upon making an election under section 897(i) (including any retroactive election) must qualify as a U.S. real property holding corporation as defined in paragraph (b)(1) of § 1.897-2.
# (c) Effective Date.
Section 1.897-8T shall be effective as of June 6, 1988, with respect to foreign corporations making an election under section 897(i) after May 5, 1988.
[T.D. 8198, 53 FR 16229, May 5, 1988]
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In this part (40 sections)
- 1.892-3 · Income of foreign governments.
- 1.892-3T · Income of foreign governments (temporary regulations).
- 1.892-4 · Commercial activities.
- 1.892-4T · Commercial activities (temporary regulations).
- 1.892-5 · Controlled commercial entity.
- 1.892-5T · Controlled commercial entity (temporary regulations).
- 1.892-6T · Income of international organizations (temporary…
- 1.892-7T · Relationship to other Internal Revenue Code sections…
- 1.893-1 · Compensation of employees of foreign governments or…
- 1.894-1 · Income affected by treaty.
- 1.895-1 · Income derived by a foreign central bank of issue, or by Bank…
- 1.897-1 · Taxation of foreign investment in United States real property…
- 1.897-2 · United States real property holding corporations.
- 1.897-3 · Election by foreign corporation to be treated as a domestic…
- 1.897-4AT · Table of contents (temporary).
- 1.897-5 · Corporate distributions.
- 1.897-5T · Corporate distributions (temporary).
- 1.897-6T · Nonrecognition exchanges applicable to corporations, their…
- 1.897-7 · Treatment of certain partnership interests, trusts and…
- 1.897-7T · Treatment of certain partnership interests as entirely U.S.…
- 1.897-8T · Status as a U.S. real property holding corporation as a…
- 1.897-9T · Treatment of certain interest in publicly traded…
- 1.897(l)-1 · (l)-1 Exception for interests held by foreign pension…
- 1.901-1 · Allowance of credit for foreign income taxes.
- 1.901-2 · Income, war profits, or excess profits tax paid or accrued.
- 1.901-2A · Dual capacity taxpayers.
- 1.901-3 · Reduction in amount of foreign taxes on foreign mineral…
- 1.901(j)-1 · (j)-1 Denial of foreign tax credit with respect to certain…
- 1.901(m)-1 · (m)-1 Definitions.
- 1.901(m)-2 · (m)-2 Covered asset acquisitions and relevant foreign…
- 1.901(m)-3 · (m)-3 Disqualified tax amount and aggregate basis…
- 1.901(m)-4 · (m)-4 Determination of basis difference.
- 1.901(m)-5 · (m)-5 Basis difference taken into account.
- 1.901(m)-6 · (m)-6 Successor rules.
- 1.901(m)-7 · (m)-7 De minimis rules.
- 1.901(m)-8 · (m)-8 Miscellaneous.
- 1.902-0 · Outline of regulations provisions for section 902.
- 1.902-1 · Credit for domestic corporate shareholder of a foreign…
- 1.902-2 · Treatment of deficits in post-1986 undistributed earnings and…
- 1.902-3 · Credit for domestic corporate shareholder of a foreign…