a united states real property interest $($USRPI$)$ is sold by a non$-$resident foreign corporation. The sales price for the USRPI is $$20$ million. Assume that the special withholding rate for residences where the amound realized is less than $1$ million is not applicable. Which of the following is the correct percentage for the amound of section $1445$ withholding that should occur on the transaction?