USRPI definition

USRPI means “United States real property interest” as defined in Section 897(c)(1) of the Code, and Treasury Regulation Section 1.897-1(c).

USRPI means United States real property interest, as defined in the Code; and

USRPI has the meaning set forth in Section 4.6(c).

Examples of USRPI in a sentence

• Loans secured by real property located in the United States that do not provide the lender with a participation in profits, gains, appreciation (or similar arrangements) of the real property are generally not treated as USRPIs.In addition, stock of a domestic corporation (including a REIT such as us) will be a USRPI if at least 50% of its real property assets and assets used in a trade or business are USRPIs at any time during a prescribed testing period.

• Subject to the FIRPTA look-through rule, (i) if our shares are a USRPI, gain from a liquidating distribution with respect our shares would be ECI to the non-U.S. shareholder unless such non-U.S. shareholder were a qualified shareholder or qualified foreign pension fund, as described above, and (ii) if our shares are not a USRPI, gain from a liquidating distribution with respect to our shares would not be subject to U.S. federal income tax.

• Further, to the extent such treatment applies, any distribution to such shareholder will not be treated as gain recognized from the sale or exchange of a USRPI.

• Even in the event our common shares are not a USRPI, we may choose to withhold on the entire amount of any distribution at the same rate as we would withhold on a dividend because we may not be able to determine at the time we make a distribution whether or not the distribution will exceed our current and accumulated earnings and profits.

• Subject to the exception that may apply if our common shares were regularly traded on an established securities market (as described above), if our shares are a USRPI, gain from the sale of our shares would be ECI to the non-U.S. shareholder unless such non-U.S. shareholder were a qualified shareholder or qualified foreign pension fund, each as described below.

More Definitions of USRPI

USRPI. ’ means a U.S. real property interest as defined under Section 897(c) of the Internal Revenue Code.

USRPI means US real property interests;

USRPI shall have the meaning set forth in Section 3.2(f).

USRPI has the meaning given to such term in Section 3.12(d).

USRPI has the meaning ascribed thereto in Section 4.11.

USRPI has the meaning given that term in Section 5.08(c).

USRPI has the meaning set forth in Section 897(c) and Section 897(g) of the Code.