United States real property holding corporation
(2) United States real property holding corporation The term “United States real property holding corporation” means 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.