net United States real property gain
(2) Minimum tax on nonresident alien individuals (A) In general In the case of any nonresident alien individual, the taxable excess for purposes of section 55(b)(1) shall not be less than the lesser of— (i) the individual’s alternative minimum taxable income (as defined in section 55(b)(1)(D) ) for the taxable year, or (ii) the individual’s net United States real property gain for the taxable year. (B) Net United States real property gain For purposes of subparagraph (A), the term “net United States real property gain” means the excess of— (i) the aggregate of the gains for the taxable year from dispositions of United States real property interests, over (ii) the aggregate of the losses for the taxable year from dispositions of such interests.