Page:United States Statutes at Large Volume 78.djvu/864

 822

PUBLIC LAW 88-563-SEPT. 2, 1964

[78 STAT.

" (B) in connection with the liquidation by such United States person (or by one or more such includible corporations) of a foreign corporation all of the outstanding stock of which, except for qualifying shares, is owned by such United States person (or by one or more such includible corporations), but only if such debt obligation had been received by such foreign corporation as part or all of the purchase price in a sale of substantially all of its assets. "(2) LIMITATION.—Paragraph (1) shall not apply to the acquisition of a debt obligation if any of the stock sold or surrendered in connection with its acquisition was originally acquired with the intent to sell or surrender. " (h) CERTAIN DEBT MORTGAGES, ETC.—

OBLIGATIONS SECURED BY UNITED STATES

"(1) IN GENERAL.—The tax imposed by section 4911 shall not apply to the acquisition from a foreign obligor by a United States person of a debt obligation of such foreign obligor which is secured by real property located in the United States, to the extent that— " (A) the debt obligation is a part of the purchase price of such real property (or of such real property and related personal property); or " (B) the debt obligation arises out of a loan made by such United States person to the foreign obligor the proceeds of which are concurrently used as part of the purchase price of such real property (or of such real property and related personal property). "(2) LIMITATION.—Paragraph (1) shall apply to the acquisition of a debt obligation only if— " (A) the owner of the property sold is a United States person; and " (B) at least 25 percent of the purchase price of the property sold is, at the time of such sale, paid in United States currency to such United States person by the foreign obligor from funds not obtained from United States persons for the purpose of purchasing such property. " (3) RELATED PERSONAL PROPERTY.—For purposes of paragraph

(1), the term 'related personal property' means personal property which is sold in connection with the sale of real property for use in the operation of such real property, " (i) ACQUISITIONS or STOCK OF FOREIGN ISSUERS INVESTING EXCLUSIVELY I N THE UNITED STATES.—

76 Stat. 1003. ^^ ^ ^^^"

Post, p. 836.

"(1) IN GENERAL.—The tax imposed by section 4911 shall not apply to the acquisition from a foreign issuer of its stock by a United States person who is a bona fide resident of a foreign country within the meaning of section 911(a)(1), or who at the time of such acquisition is regularly performing personal services on a full-time basis in a foreign country, if at the close of each calendar quarter ending on or after June 30, 1963, preceding such acquisition, during any part of which such foreign issuer is in existence— " (A) the assets of such foreign issuer, exclusive of money or deposits with persons carrying on the banking business, consist solely of: " (i) stock or debt obligations of domestic corporations (other than a corporation which has elected under section 4920(a)(3)(B) to be treated as a foreign issuer or obligor for purposes of this chapter);

�