Which of the Following Statements Regarding the Taxation of U

Which of the following statements regarding the taxation of U.S.real property gains recognized by foreign persons not engaged in a U.S.trade or business is not true?

A) Gains from the disposition of U.S. real property are taxed to foreign persons notwithstanding the general exemption of capital gains from U.S. taxation.
B) Gains from the disposition of U.S. real property are not taxed to foreign persons because real property gains are specifically exempt from U.S. taxation.
C) Gains from the disposition of U.S. real property are taxed in the U.S. because such gains are treated as if they are effectively connected to a U.S. trade or business.
D) Gains from the disposition of U.S. real property are taxed to foreign persons without regard to whether such foreign persons are engaged in a U.S. trade or business.
E) None of the above.