Revenue Reconciliation Act of 1980

[AI summary unavailable — showing source text] Revenue Reconciliation Act of 1980 - Subtitle A: Taxation of Foreign Investment in United States Real Property - Foreign Investment in Real Property Tax Act of 1980 - Amends the Internal Revenue Code to impose on a nonresident alien or foreign corporation a tax of 28 percent of the excess over $5,000 (if any) of the net capital gains realized by the taxpayer during the taxable year from the sale of United States real property interests. Defines "U.S. real property interest" as either: (1) an interest in real property located in the United States; or (2) any interest (other than solely as a creditor) in any corporation, partnership, or trust which was in a U.S. real property holding organization (a business entity in which a controlling interest is held by ten or fewer individuals and of which U.S. real property interests constitute more than 50 percent of the fair market value of the organization) for up to five years prior to such sale. Includes within the term "interest in real property" fee ownership and co-ownership of land or improvements thereon, leaseholds of land or improvements, and options to acquire such leaseholds of land or improvements. States that nonrecognition prov…