Form instructions:
Box 2e. Shows the portion of the amount in box 1a that is section 897 gain
attributable to disposition of U.S. real property interests (USRPI).
Box 2f. Shows the portion of the amount in box 2a that is section 897 gain
attributable to disposition of USRPI.
Note: Boxes 2e and 2f apply only to foreign persons and entities whose income
maintains its character when passed through or distributed to its direct or
indirect foreign owners or beneficiaries. It is generally treated as effectively
connected to a trade or business within the United States