Hans a citizen and resident of Argentina is a retired bank executive. Hans doe

Hans a citizen and resident of Argentina is a retired bank executive. Hans does not hold a green card. At the start of Year 1 Hans paid $2.5 million
for a 20-unit apartment complex located in the suburbs of Washington D.C. Hans does not actively manage the building but rather leases it to an
unrelated property management company that subleases the building to the tenants. During Year 1 Hans had rental income of $300000 and operating
expenses (depreciation interest insurance etc.) of $220000. On the advice of his accountant Hans made a Code Sec. 871(d) election in Year 1. At
the start of Year 2 Hans sold the building for $350000. Hans%u2019 adjusted basis in the building at that time was $290000.

What are the U.S. tax consequences of Hans%u2019 U.S. activities?