### Question
How is the "United States real property holding corporation" defined?


### Answer
The term **United States real property holding corporation** is defined in *26 U.S.C. § 897* as follows -

> any corporation if—



(A) the fair market value of its United States real property interests equals or exceeds 50 percent of



(B) the fair market value of—



(i) its United States real property interests,



(ii) its interests in real property located outside the United States, plus



(iii) any other of its assets which are used or held for use in a trade or business

#### 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**

