Which of the following statements regarding the taxation of U.S. real property gains recognized by non-U.S. persons not engaged in a U.S. trade or business is false? Gains from the disposition of U.S. real property are: o Not taxed to non-U.S. persons because real property gains are specifically exempt from U.S. taxation. O Taxed to non-U.S. persons without regard to whether such non-U.S. persons are engaged in a U.S. trade or business. O Taxed in the U.S. because such gains are treated as if they are effectively connected to a U.S. trade or business. O Taxed to non-U.S. persons notwithstanding the general exemption of capital gains from U.S. taxation. O None of the above