Article 225-4Income Arising from the Transfer of Assets Located Outside Japan

一real property located outside Japan;

二a right on real property located outside Japan, a mining right outside Japan or a quarrying right outside Japan;

三forested land located outside Japan;

四shares issued by a Foreign Corporation or an investor's interest in a Foreign Corporation, on the transfer of which, where shares or contributions equivalent in number or amount to a certain proportion or more of the total number or total amount of issued shares or contributions of that Foreign Corporation are owned, foreign income tax is imposed on the income arising from the transfer in the country or region where the head office or principal office of that Foreign Corporation is located;

五shares of a real estate-related corporation (including contributions and investment units prescribed in Article 2, paragraph (14) (Definitions) of the Act on Investment Trusts and Investment Corporations; the same applies in the following item and the following paragraph);

六where owning the shares of a corporation pertaining to the ownership or management of a golf course located outside Japan is required so that the owner becomes a person entitled to use the golf course continuously under advantageous terms compared to general users, those shares;

七the right concerning the utilization of golf courses or other facilities located outside Japan.

一land, etc. located outside Japan (meaning land or a right on land, buildings and their associated facilities, or structures; hereinafter the same applies in this paragraph);

二shares of a corporation for which the rate of the sum of the values of land, etc. located outside Japan accounts for 50 percent or more of the total amount of its gross assets;

三shares (excluding those falling under shares listed in the preceding item) of a corporation which owns shares listed in the preceding item or the following item (limited to a corporation for which the rate of the sum of the values of land, etc. located outside Japan and shares listed in the preceding item, this item, and the following item accounts for 50 percent or more of the total amount of its gross assets);

四shares (excluding those falling under shares listed in the preceding two items) of a corporation which owns shares listed in the preceding item (limited to a corporation for which the rate of the sum of the values of land, etc. located outside Japan and shares listed in the preceding two items and this item accounts for 50 percent or more of the total amount of its gross assets).