Code of Federal Regulations Title 26. Internal Revenue § 26.1.897–7 Treatment of certain partnership interests, trusts and estates under section 897(g)

(a) through (b) [Reserved]. For further guidance, see § 1.897–7T(a) through (b).

(c) Coordination with section 864(c)(8). Except as provided in § 1.864(c)(8)–1, the amount of any money, and the fair market value of any property, received by a nonresident alien individual or foreign corporation in exchange for all or part of its interest in a partnership, trust, or estate will, to the extent attributable to United States real property interests, be considered as an amount received from the sale or exchange in the United States of such property. See also § 1.864(c)(8)–1(h) for an anti-stuffing rule that may apply to transactions subject to section 897. This paragraph applies to transfers occurring on or after December 26, 2018, and to amounts received on or after December 26, 2018, pursuant to an installment sale (as defined in section 453(b)) occurring on or after November 27, 2017.