### Question
How is the term USRPI gain defined?


### Answer
The term **USRPI gain** is defined in *26 U.S.C. § 897* as the following:

> the excess (if any) of—


(i) the sum of—


(I) any gain recognized from the disposition of a United States real property interest, and


(II) any distribution by a real estate investment trust that is treated as gain recognized from the sale or exchange of a United States real property interest, over


  

(ii) any loss recognized from the disposition of a United States real property interest

#### Citation:
  - *26 U.S.C. § 897*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART II-NONRESIDENT ALIENS AND FOREIGN CORPORATIONS > Subpart D-Miscellaneous Provisions**

