From Typepad.com: Wei Cui (China University of Political Science and Law) has posted Is Section 892 the Right Place to Look for a Response to Sovereign Wealth Funds?, 123 Tax Notes 1237 (June 8, 2009), on SSRN. Here is the abstract:

At a superficial glance, Internal Revenue Code Section 892 appears to favor sovereign wealth funds (SWFs) over foreign private investors by exempting the former from tax on a significant range of US investments…….Full Article: Source