WHEN PARTNERSHIPS DISPOSE OF US REAL PROPERTY INTERESTS (usrpis), the presence of nonresident alien partners will

REQUIRE THAT THE FOREIGN PARTNERS HAVE THEIR US INCOME TAX FILING REQUIREMENTS SATISIFIED BY PARTNERSHIP

REQUIRE THE FOREIGN PARTNERS MAKE A CAPITAL CONTRIBUTION TO THE PARTNERSHIP FOR THE FIRPTA TAX

REQUIRE WITHHOLDING WHICH WILL DIFFER WHETHER PARTNERSHIP IS DOMESTIC OR FOREIGN

REQUIRE A GAIN ALLOCATION TO THE DOMESTIC PARTNERS ONLY