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this is our disclaimer which iamp;#39;m required to pause on for a minute okay so i think the i think the first thing to start off with is context i think context is really big you have to have context to kind of understand how tax rules work and so we have to go in the time machine back to 1980 and thatamp;#39;s when ferpda was introduced and so um we see that that came through in uh starting in 1981 so the legislation was passed in 1980 at the very end of the year and goes into effect starting in 1981 but prior to the legislation uh if you were a non-resident alien and you owned u.s real property and you sold it there was no tax due on the sale of that real property and in the united states we donamp;#39;t have any prohibitions against non-us people owning u.s rural property so prior to 1981 you could have owned any type of real property sold it and not had any kind of tax supply but in 1980 end of the year they they passed the uh the fripta and the original amount the original ho