income of nonresident alien individuals limited to gains on United States real property interests In the case of any individual to whom clause (i) applies, the tax imposed under section 1 on such individual (after application of clause (ii)(II)) shall be reduced (but not below zero) by the excess of— (I) the tax which would be imposed under such section (after application of clause (ii)(II)) if FIRPTA items were not taken into account, over (II) the tax which would be imposed under such section if FIRPTA items were not taken into account, and clause (ii)(II) did not apply. For purposes of this clause, the term FIRPTA items means gains and losses taken into account under section 871(b)(1) by reason of section 897(a)(1)(A). (B) Withholding taxes (i) In general In the case of any payment to an applicable person after the applicable date, the rate of tax specified in sections 1441(a) and 1442(a) (other than the 14 percent rate of tax specified in section 1441(a)) shall each be increased by the applicable number of percentage points. (ii) Disposition of United States real property interests In the case of any disposition of a United States real property interest (as defined in section 897(c)) by an applicable person after the applicable date, the rate of tax specified in section 1445(a) shall be increased by the applicable number of percentage points. (iii) Other dispositions and distributions related to United States real property interests In the case of any disposition or distribution described in any paragraph of section 1445(e) made after the applicable date, each rate of tax in such paragraph shall be increased by the applicable number of percentage points if— (I) in the case of section 1445(e)(1), the foreign person referred to in subparagraph (A) or (B) of such section is an applicable person, (II) in the case of section 1445(e)(2), the foreign corporation referred to in such section is an applicable person, (III) in the case of section 1445(e)(3), the foreign shareholder referred to in such section is an