The US Treasury Department and the Internal Revenue Service (IRS) have issued a notice requesting comments concerning IRS Notice 2006-46 (Announcement of Rules to be Included in Final Regulations under Section 89(d) and (e) of the Internal Revenue Code (IRC)). The disposition of a US real property interest (USRPI) by a non-resident alien individual or foreign corporation is taxable under FIRPTA (Foreign Investment in Real Property Tax Act), codified as IRC section 897. IRC section 897(a) imposes tax on such dispositions as if the taxpayer were engaged in a trade or business within the United States and the gain or loss were effectively connected...