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26 U.S.C. § 1443 — Foreign tax-exempt organizations
Federal law — U.S. Code and appendices · legal_authorities
**(a) Income subject to section 511** In the case of income of a foreign organization subject to the tax imposed by section 511, this chapter shall apply to income includible under section 512 in computing its unrelated business taxable income, but only to the extent and subject to such conditions as may be provided under regulations prescribed by the Secretary.
**(b) Income subject to section 4948** In the case of income of a foreign organization subject to the tax imposed by section 4948(a), this chapter shall apply, except that the deduction and withholding shall be at the rate of 4 percent and shall be subject to such conditions as may be provided under regulations prescribed by the Secretary.
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Source location: Title 26, Chapter 3, § 1443; chapter-003-withholding-of-tax-on-nonresident-aliens-and-foreign-corporations.md
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**(a) Income subject to section 511** In the case of income of a foreign organization subject to the tax imposed by section 511, this chapter shall apply to income includible under section 512 in computing its unrelated business taxable income, but only to the extent and subject to such conditions as may be provided under regulations prescribed by the Secretary.
**(b) Income subject to section 4948** In the case of income of a foreign organization subject to the tax imposed by section 4948(a), this chapter shall apply, except that the deduction and withholding shall be at the rate of 4 percent and shall be subject to such conditions as may be provided under regulations prescribed by the Secretary.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Tax-exempt foundations** There is hereby imposed on each private foundation which is exempt from taxation under section 501(a) for the taxable year, with respect to the carrying on of its activities, a tax equal to 1.39 percent of the net investment income of such foundation for the taxable year.
**(b) Taxable foundations** There is hereby imposed on each private foundation which is not exempt from taxation under section 501(a) for the taxable year, with respect to the carrying on of its activities, a tax equal to—
(1) the amount (if any) by which the sum of (A) the tax imposed under subsection (a) (computed as if such subsection applied to such private foundation for the taxable year), plus (B) the amount of the tax which would have been imposed under section 511 for the taxable year if such private foundation had been exempt from taxation under section 501(a), exceeds
(2) the tax imposed under subtitle A on such private foundation for the taxable year.
**(c) Net investment income defined**
(1) **In general** — For purposes of subsection (a), the net investment income is the amount by which (A) the sum of the gross investment income and the capital gain net income exceeds (B) the deductions allowed by paragraph (3). Except to the extent inconsistent with the provisions of this section, net investment income shall be determined under the principles of subtitle A.
(2) **Gross investment income** — For purposes of paragraph (1), the term “gross investment income” means the gross amount of income from interest, dividends, rents, payments with respect to securities loans (as defined in section 512(a)(5)), and royalties, but not including any such income to the extent included in computing the tax imposed by section 511. Such term shall also include income from s
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Charitable, etc., organizations taxable at corporation rates**
(1) **Imposition of tax** — There is hereby imposed for each taxable year on the unrelated business taxable income (as defined in section 512) of every organization described in paragraph (2) a tax computed as provided in section 11. In making such computation for purposes of this section, the term “taxable income” as used in section 11 shall be read as “unrelated business taxable income”.
(2) **Organizations subject to tax**
(A) *Organizations described in sections 401(a) and 501(c)* — The tax imposed by paragraph (1) shall apply in the case of any organization (other than a trust described in subsection (b) or an organization described in section 501(c)(1)) which is exempt, except as provided in this part or part II (relating to private foundations), from taxation under this subtitle by reason of section 501(a).
(B) *State colleges and universities* — The tax imposed by paragraph (1) shall apply in the case of any college or university which is an agency or instrumentality of any government or any political subdivision thereof, or which is owned or operated by a government or any political subdivision thereof, or by any agency or instrumentality of one or more governments or political subdivisions. Such tax shall also apply in the case of any corporation wholly owned by one or more such colleges or universities.
**(b) Tax on charitable, etc., trusts**
(1) **Imposition of tax** — There is hereby imposed for each taxable year on the unrelated business taxable income of every trust described in paragraph (2) a tax computed as provided in section 1(e). In making such computation for purposes of this section, the term “taxable income” as used in section 1 shall be read as “unrelated business tax
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Federal law — U.S. Code and appendices · legal_authorities
Page 2531
TITLE 26—INTERNAL REVENUE CODE
§ 1444
with the conduct of a trade or business in the United
States and authorized the granting of an exemption
from the withholding requirement in the case of a for-
eign corporation engaged in trade or business within
the United States if the Secretary or his delegate de-
termines that the withholding imposes an undue ad-
ministrative burden and that the collection of the tax
will not be jeopardized by the exemption.
Statutory Notes and Related Subsidiaries
EFFECTIVE DATE OF 2004 AMENDMENT
Amendment by section 411(a)(3)(B) of Pub. L. 108–357
applicable to dividends with respect to taxable years of
regulated investment companies beginning after Dec.
31, 2004, see section 411(d)(1) of Pub. L. 108–357, set out
as a note under section 871 of this title.
Amendment by section 420(b) of Pub. L. 108–357 appli-
cable to dividends paid after Oct. 22, 2004, see section
420(d) of Pub. L. 108–357, set out as a note under section
881 of this title.
EFFECTIVE DATE OF 1993 AMENDMENT
Amendment by Pub. L. 103–66 applicable to interest
received after Dec. 31, 1993, see section 13237(d) of Pub.
L. 103–66, set out as a note under section 871 of this
title.
EFFECTIVE DATE OF 1988 AMENDMENT
Amendment by Pub. L. 100–647 effective, except as
otherwise provided, as if included in the provision of
the Tax Reform Act of 1986, Pub. L. 99–514, to which
such amendment relates, see section 1019(a) of Pub. L.
100–647, set out as a note under section 1 of this title.
EFFECTIVE DATE OF 1986 AMENDMENT
Amendment by section 1273(b)(2)(B) of Pub. L. 99–514
applicable to taxable years beginning after Dec. 31,
1986, with certain exceptions and qualifications, see
section 1277 of Pub. L. 99–514, set out as a note under
section 931 of this
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