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IRC section 897(g) treats a partnership interest as a USRPI only to the extent the gain on the disposition is attributable to USRPI.

IRC section 897(g) does not treat a partnership interest as a USRPI to the extent the gain on the disposition is attributable to cash, cash equivalents or other property.

The directory lists more than 1,200 real estate properties and 10,000 key companies owned by foreign investors.

All withholding certificate applications and FIRPTA tax returns are filed at the Philadelphia Service Center (PSC).

The type of information maintained varies depending on the Federal department.

Some information maintained may be related to foreign entities and transactions involving foreign persons.

The PSC maintains a FIRPTA data base that is available to all IEs.

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This data base includes the following information: The business section of public libraries may have this directory.

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