Returns with respect to foreign persons holding direct investments in United States real property interests

To the extent provided in regulations, any foreign person holding direct investments in United States real property interests for the calendar year shall make a return setting forth— For purposes of this section, a foreign person shall be treated as holding direct investments in United States real property interests during any calendar year if— For purposes of this section— The term “United States real property interest” has the meaning given to such term by section 897(c). The term “foreign person” means any person who is not a United States person. For purposes of subsection (b)(2)— United States real property interests held by a partnership, trust, or estate shall be treated as owned proportionately by its partners or beneficiaries. United States real property interests held by the spouse or any minor child of an individual shall be treated as owned by such individual. All returns required to be made under this section shall be made at such time and in such manner as the Secretary shall by regulations prescribe. A nonresident alien individual or foreign corporation subject to tax under section 897(a) (and any person required to withhold tax under section 1445) shall pay any tax and file any return required by this title—