PUBLIC LAW 96-499—DEC. 5, 1980
94 STAT. 2689
"(C) INDIRECT HOLDINGS.—The assets of any entity to which this subsection applies shall include its pro rata share of the United States real property interests held by any corporation in which the entity is a substantial investor in United States real property. "(c) RETURN OF CERTAIN FOREIGN PERSONS HOLDING DIRECT INVESTMENTS IN UNITED STATES REAL PROPERTY INTERESTS.— "(1) RETURN REQUIREMENT.—If this subsection applies to any
foreign person for the calendar year, such person shall make a return for the calendar year setting forth— "(A) the name and address of such person, "(B) a description of all United States real property interests held by such person at any time during the calendar year, and "(C) such other information as the Secretary may by regulations prescribe. "(2) PERSONS TO WHOM THIS SUBSECTION APPLIES.—This subsec-
tion applies to any foreign person for the calendar year if— '(A) such person did not engage in a trade or business in the United States at any time during the calendar year, "(B) the fair market value of the United States real property interests held by such person at any time during such year equals or exceeds $50,000, and "(C) such person is not required to file a return under subsection (b) of such year. "(d) DEFINITIONS.—For purposes of this section— "(1) UNITED STATES REAL PROPERTY INTEREST.—The term 'United States real property interest' has the meaning given to such term by section 897(c). Ante, p. 2682. "(2) FOREIGN PERSON.—The term 'foreign person' means any person who is not a Uh|ted States person." "(e) SPECIAL RULES.—
"(1) ATTRIBUTION OF OWNERSHIP.—For purposes of subsections
(b)(4) and (c)(2)(B)— "(A) INTERESTS HELD BY PARTNERSHIPS, ETC.—United States real property interests held by a partnership, trust, or estate shall be treated as owned proportionately by its partners or beneficiaries. "(B) INTERESTS HELD BY FAMILY MEMBERS.—United States real property interests held by the spouse or any minor child of an individual shall be treated as owned by such individual. "(2) RETURNS, ETC.—All returns, statements, and information required to be made or furnished under this section shall be made or furnished at such time and in such manner as the Secretary shall by regulations prescribe." (b) PENALTY FOR FAILURE TO FILE RETURN, ETC.—Section 6652 of 26 USC 6652. such Code (relating to failure to file certain information returns, registration statements, etc.) is amended by redesignating subsection (g) as subsection (h) and by inserting after subsection (f) the following new subsection: "(g) RETURNS, ETC., REQUIRED UNDER SECTION 6039C.— Ante, p. 2687. "(1) IN GENERAL.—In the case of each failure— "(A) to make a return required by section 6039C which contains the information required by such section, or "(B) to furnish a statement required by section 6039C(b)(3), on the date prescribed therefor (determined with regard to any extension of time for filing), unless it is shown that such failure is due to reasonable cause and not to willful neglect, the amount
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