The article focuses on the revenue ruling, Rev. Rul. 2008-31, for taxation of foreign investment in U.S. real property investment (USRPI). It cites that gain or loss of a foreign corporation from the disposition of a USRPI shall be taken into account. According to the article, USRPI is defined by the Internal Revenue Code as "an interest in real property located in the U.S. or the Virgin Islands and any interest in any domestic corporation."