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

(a) Required return Section 6039C(a) of the Internal Revenue Code of 1986 is amended by striking To the extent provided in regulations, any and inserting Any. (b) Dollar threshold removed Section 6039C(b) of such Code is amended by striking during any calendar year if— and all that follows through the period and inserting during any calendar year if such person did not engage in a trade or business in the United States at any time during such calendar year. (c) Effective date The amendments made by this section shall apply to returns filed with respect to taxable years beginning after the date of the enactment of this Act.