SECTION 2. BACKGROUND

.01 Section 897(a)(1) of the Internal Revenue Code treats the gain or loss of a nonresident alien or foreign corporation from the disposition of a U.S. real property interest as if the taxpayer were engaged in a trade or business in the United States, and as if such gain or loss were effectively

26 CFR 1.956–1: Definition of United States prop- erty. (Also: 956(c)(2)(J).)

Rev. Proc. 2008–26