Under the US tax laws, foreign persons are typically not subject to US tax payment and US tax filing requirements with respect to US-source capital gains, unless such capital gains are treated as (or deemed to be) income that is effectively connected with the conduct of a trade or business in the United States (“Effectively Connected Income”). FIRPTA includes within Effectively Connected Income: (i) gains from the sale or disposition of a “United States real property interest” (“USRPI”), which includes shares in a “United States real property holding corporation,” and (ii) distributions from a REIT of amounts that are attributable to the disposition by the REIT of a USRPI (“capital gain dividends”).