94 STAT. 2690
PUBLIC LAW 96-499—DEC. 5, 1980 determined under paragraph (2) shall be paid (upon notice and demand by the Secretary and in the same manner as tax) by the person failing to make such return or furnish such statement. "(2) AMOUNT OF PENALTY.—For purposes of paragraph (1), the
amount determined under this paragraph with respect to any failure shall be $25 for each day during which such failure continues. "(3) LIMITATIONS.— "(A) FOR FAILURE TO MEET REQUIREMENTS OF SUBSECTION (A)
Ante, p. 2687.
QR (B) OF SECTION 6039C.—The amount determined under paragraph (2) with respect to any person for failing to meet the requirements of subsection (a) or (b) of section 6039C for any calendar year shall not exceed $25,000 with respect to each such subsection. "(B) FOR FAILURE TO MEET REQUIREMENTS OF SECTION
6039C(C).—The amount determined under paragraph (2) with respect to any person for failing to meet the requirements of subsection (c) of section 6039C for any calendar year shall not exceed the lesser of $25,000 or 5 percent of the aggregate of the fair market value of the United States real property interests owned by such person at any time during such year. For purposes of the preceding sentence, fair market value shall be determined as of the end of the calendar year (or, in the case of any property disposed of during the calendar year, as of the date of such disposition)." (c) CLERICAL AMENDMENT.—The table of sections for subpart A of part III of chapter 61 of such Code is amended by inserting after the item relating to section 6039B the following new item: "Sec.
6039C. Returns with respect to United States real property interests."
SEC. 1124. SOURCES WITHIN UNITED STATES.
26 USC 861.
Paragraph (5) of subsection (a) of section 861 of the Internal Revenue Code of 1954 (relating to income from sources within the United States) is amended to read as follows: "(5) DISPOSITION OF UNITED STATES REAL PROPERTY INTEREST.—
Gains, profits, and income from the disposition of a United States Ante, p. 2682. real property interest (as defined in section 897(c))." SEC. 1125. EFFECTIVE DATE. 26 USC 897 note. (a) IN GENERAL.—Except as provided in subsection (b), the amendments made by this subtitle shall apply to dispositions after June 18, 1980. O> REPORTING.—The amendments made by section 1123 shall apply t) to 1980 and subsequent calendar years. In applying such amendments to 1980, such calendar year shall be treated as beginning on June 19, 1980, and ending on December 31, 1980. (c) SPECIAL RULE FOR TREATIES.—
26 USC 894, 26 USC 871, 882. Ante, p. 2682.
(1) IN GENERAL.—Except as provided in paragraph (2), after December 31, 1984, nothing in section 894(a) or 7852(d) of the Internal Revenue Code of 1954 or in any other provision of law shall be treated as requiring, by reason of any treaty obligation of the United States, an exemption from (or reduction oD any tax imposed by section 871 or 882 of such Code on a gain described in section 897 of such Code. (2) SPECIAL RULE FOR TREATIES RENEGOTIATED BEFORE I 9 8 5. —
If—
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