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26 U.S.C. § 887 — Imposition of tax on gross transportation income of nonresident aliens and foreign corporations
Federal law — U.S. Code and appendices · legal_authorities
**(a) Imposition of tax** In the case of any nonresident alien individual or foreign corporation, there is hereby imposed for each taxable year a tax equal to 4 percent of such individual’s or corporation’s United States source gross transportation income for such taxable year.
**(b) United States source gross transportation income**
(1) **In general** — Except as provided in paragraphs (2) and (3), the term “United States source gross transportation income” means any gross income which is transportation income (as defined in section 863(c)(3)) to the extent such income is treated as from sources in the United States under section 863(c)(2). To the extent provided in regulations, such term does not include any income of a kind to which an exemption under paragraph (1) or (2) of section 883(a) would not apply.
(2) **Exception for certain income effectively connected with business in the United States** — The term “United States source gross transportation income” shall not include any income taxable under section 871(b) or 882.
(3) **Exception for certain income taxable in possessions** — The term “United States source gross transportation income” does not include any income taxable in a possession of the United States under the provisions of this title as made applicable in such possession.
(4) **Determination of effectively connected income** — For purposes of this chapter, United States source gross transportation income of any taxpayer shall not be treated as effectively connected with the conduct of a trade or business in the United States unless—
(A) the taxpayer has a fixed place of business in the United States involved in the earning of United States source gross transportation income, and
(B) substantially all of the United States source gross transp
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Source file: Laws/federal/codes/united-states-code/title-26/section-887-imposition-of-tax-on-gross-transportation-income-of-nonresident-aliens-a--92f880555b.md
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Source location: Title 26, Chapter 1, § 887; chapter-001-normal-taxes-and-surtaxes.md
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**(a) Imposition of tax** In the case of any nonresident alien individual or foreign corporation, there is hereby imposed for each taxable year a tax equal to 4 percent of such individual’s or corporation’s United States source gross transportation income for such taxable year.
**(b) United States source gross transportation income**
(1) **In general** — Except as provided in paragraphs (2) and (3), the term “United States source gross transportation income” means any gross income which is transportation income (as defined in section 863(c)(3)) to the extent such income is treated as from sources in the United States under section 863(c)(2). To the extent provided in regulations, such term does not include any income of a kind to which an exemption under paragraph (1) or (2) of section 883(a) would not apply.
(2) **Exception for certain income effectively connected with business in the United States** — The term “United States source gross transportation income” shall not include any income taxable under section 871(b) or 882.
(3) **Exception for certain income taxable in possessions** — The term “United States source gross transportation income” does not include any income taxable in a possession of the United States under the provisions of this title as made applicable in such possession.
(4) **Determination of effectively connected income** — For purposes of this chapter, United States source gross transportation income of any taxpayer shall not be treated as effectively connected with the conduct of a trade or business in the United States unless—
(A) the taxpayer has a fixed place of business in the United States involved in the earning of United States source gross transportation income, and
(B) substantially all of the United States source gross transportation income (determined without regard to paragraph (2)) of the taxpayer is attributable to regularly scheduled transportation (or, in the case of income from the leasing of a vessel or aircraft, is attributable to a fixed place of business in the United States).
**(c) Coordination with other provisions** Any income taxable under this section shall not be taxable under section 871, 881, or 882.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Allocation under regulations** Items of gross income, expenses, losses, and deductions, other than those specified in sections 861(a) and 862(a), shall be allocated or apportioned to sources within or without the United States, under regulations prescribed by the Secretary. Where items of gross income are separately allocated to sources within the United States, there shall be deducted (for the purpose of computing the taxable income therefrom) the expenses, losses, and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income. The remainder, if any, shall be included in full as taxable income from sources within the United States.
**(b) Income partly from within and partly from without the United States** In the case of gross income derived from sources partly within and partly without the United States, the taxable income may first be computed by deducting the expenses, losses, or other deductions apportioned or allocated thereto and a ratable part of any expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income; and the portion of such taxable income attributable to sources within the United States may be determined by processes or formulas of general apportionment prescribed by the Secretary. Gains, profits, and income—
(1) from services rendered partly within and partly without the United States,
(2) from the sale or exchange of inventory property (within the meaning of section 865(i)(1)) produced (in whole or in part) by the taxpayer within and sold or exchanged without the United States, or produced (in whole or in part) by the taxpayer without and sold or exch
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 863
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Gross income from sources within United States** The following items of gross income shall be treated as income from sources within the United States:
(1) **Interest** — Interest from the United States or the District of Columbia, and interest on bonds, notes, or other interest-bearing obligations of noncorporate residents or domestic corporations not including—
(A) interest—
(i) on deposits with a foreign branch of a domestic corporation or a domestic partnership if such branch is engaged in the commercial banking business, and
(ii) on amounts satisfying the requirements of subparagraph (B) of section 871(i)(3) which are paid by a foreign branch of a domestic corporation or a domestic partnership, and
(B) in the case of a foreign partnership, which is predominantly engaged in the active conduct of a trade or business outside the United States, any interest not paid by a trade or business engaged in by the partnership in the United States and not allocable to income which is effectively connected (or treated as effectively connected) with the conduct of a trade or business in the United States.
(2) **Dividends** — The amount received as dividends—
(A) from a domestic corporation, or
(B) from a foreign corporation unless less than 25 percent of the gross income from all sources of such foreign corporation for the 3-year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was effectively connected (or treated as effectively connected other than income described in section 884(d)(2)) with the conduct of a trade or business within the United States; but only in an amount which bears the same ratio to such dividends as the gross in
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 861
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Married individuals filing joint returns and surviving spouses** There is hereby imposed on the taxable income of—
(1) every married individual (as defined in section 7703) who makes a single return jointly with his spouse under section 6013, and
(2) every surviving spouse (as defined in section 2(a)),
a tax determined in accordance with the following table: If taxable income is:The tax is: Not over $36,90015% of taxable income. Over $36,900 but not over $89,150$5,535, plus 28% of the excess over $36,900. Over $89,150 but not over $140,000$20,165, plus 31% of the excess over $89,150. Over $140,000 but not over $250,000$35,928.50, plus 36% of the excess over $140,000. Over $250,000$75,528.50, plus 39.6% of the excess over $250,000.
**(b) Heads of households** There is hereby imposed on the taxable income of every head of a household (as defined in section 2(b)) a tax determined in accordance with the following table: If taxable income is:The tax is: Not over $29,60015% of taxable income. Over $29,600 but not over $76,400$4,440, plus 28% of the excess over $29,600. Over $76,400 but not over $127,500$17,544, plus 31% of the excess over $76,400. Over $127,500 but not over $250,000$33,385, plus 36% of the excess over $127,500. Over $250,000$77,485, plus 39.6% of the excess over $250,000.
**(c) Unmarried individuals (other than surviving spouses and heads of households)** There is hereby imposed on the taxable income of every individual (other than a surviving spouse as defined in section 2(a) or the head of a household as defined in section 2(b)) who is not a married individual (as defined in section 7703) a tax determined in accordance with the following table: If taxable income is:The tax is: Not over $22,10015% of taxable income. Over $22,100 but not over $53,50
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 1
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Federal law — U.S. Code and appendices · legal_authorities
Page 2091
TITLE 26—INTERNAL REVENUE CODE
§ 887
any treaty obligation of the United States in effect on
Oct. 22, 1986, with provision that for such purposes any
amendment by title I of Pub. L. 100–647 be treated as if
it had been included in the provision of Pub. L. 99–514
to
which
such
amendment
relates,
see
section
1012(aa)(3), (4) of Pub. L. 100–647, set out as a note under
section 861 of this title.
§ 885. Cross references
(1) For special provisions relating to foreign cor-
porations carrying on an insurance business within
the United States, see section 842.
(2) For rules applicable in determining whether
any foreign corporation is engaged in trade or busi-
ness within the United States, see section 864(b).
(3) For adjustment of tax in case of corporations
of certain foreign countries, see section 896.
(4) For allowance of credit against the tax in case
of a foreign corporation having income effectively
connected with the conduct of a trade or business
within the United States, see section 906.
(5) For withholding at source of tax on income of
foreign corporations, see section 1442.
(Aug. 16, 1954, ch. 736, 68A Stat. 283, § 884; Pub. L.
89–809, title I, § 104(m)(1), Nov. 13, 1966, 80 Stat.
1563; Pub. L. 91–172, title I, § 101(j)(21), Dec. 30,
1969, 83 Stat. 528; renumbered § 885, Pub. L.
99–514, title XII, § 1241(a), Oct. 22, 1986, 100 Stat.
2576.)
Editorial Notes
AMENDMENTS
1986—Pub. L. 99–514 renumbered section 884 of this
title as this section.
1969—Pub. L. 91–172 redesignated pars. (2) to (6) as (1)
to (5), respectively. Former par. (1), referring to section
512(a), was struck out.
1966—Par. (1). Pub. L. 89–809 redesignated par. (4) as
(1). Former par. (1) redesignated (6).
Par. (2). Pub. L. 89–809 redesignated par. (3) as
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 887
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