Treasury Regulations · 26 CFR
§ 1.897-7. Treatment of certain partnership interests, trusts and estates under section 897(g).
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 897
Cite as 26 CFR § 1.897-7
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- November 6, 2020 by T.D. 9919
- Issued under
- 26 U.S.C. § 897
- Length
- 163 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 2 regulations; cited by 1
¶(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.
[T.D. 9919, 85 FR 70971, Nov. 6, 2020]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
- § 1.897-7T Treatment of certain partnership interests as entirely U.S. real property interests under sections 897(g) and 1445(e) (temporary).
- § 1.864(c)(8)-1 Gain or loss by foreign persons on the disposition of certain partnership interests.
Cited by 1 other regulation
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 9919 (85 FR 70971)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Miscellaneous provisions
Nearby sections
- § 1.897-4AT Table of contents (temporary).
- § 1.897-5 Corporate distributions.
- § 1.897-5T Corporate distributions (temporary).
- § 1.897-6T Nonrecognition exchanges applicable to corporations, their shareholders, and other taxpayers, and certain transfers of property in corporate reorganizations (temporary).
- § 1.897-7 Treatment of certain partnership interests, trusts and estates under section 897(g).
- § 1.897-7T Treatment of certain partnership interests as entirely U.S. real property interests under sections 897(g) and 1445(e) (temporary).
- § 1.897-8T Status as a U.S. real property holding corporation as a condition for electing section 897(i) pursuant to § 1.897-3 (temporary).
- § 1.897-9T Treatment of certain interest in publicly traded corporations, definition of foreign person, and foreign governments and international organizations (temporary).
- § 1.897(l)-1 Exception for interests held by foreign pension funds.