A corporation, trust, association, or partnership organized outside the laws of the United States that satisfies all of the following: a.
(a)#
At least 75 percent of the entity’s total asset value at the close of its taxable year consists of real estate assets, as defined in section 856 (c) (5) (B) of the Internal Revenue Code, cash and cash equivalents, and U.S. government securities.
(b)#
The entity is not subject to tax on amounts distributed to its beneficial owners or is exempt from entity-level taxation.
(c)#
The entity distributes at least 85 percent of its taxable income, as computed in the jurisdiction in which it is organized, to the holders of its shares or certificates of beneficial interest on an annual basis.
(d)#
Either no more than 10 percent of the voting power or value in the entity is held directly, indirectly, or constructively by a single entity or individual or the shares or beneficial interests of the entity are regularly traded on an established securities market.
(e)#
The entity is organized in a country that has a tax treaty with the United States.