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26 C.F.R. § 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).

Title 26: Internal Revenue
PART 1—INCOME TAXES
miscellaneous provisions

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§ 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).

(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]