FIRPTA Exception for Regularly Traded Stock Held by Partnerships

Pursuant to §897(c)(1)(A)(ii), stock of a domestic corporation that is (or, during the shorter of certain look-back periods, was) a U.S. real property holding corporation (“USRPHC”), as defined in §897(c)(2), generally is a U.S. real property interest (“USRPI”). However, §897(c)(3) provides an exception for certain regularly traded stock (the “regularly traded exception”). Section 897(c)(3) provides that “[i]f any class of stock of a corporation is regularly traded on an established securities market, stock of such class shall be treated as a United States real property interest only in the case of a ...