U.S. Code » Title 26 » Subtitle Subtitle A— Income Taxes › Chapter CHAPTER 1— NORMAL TAXES AND SURTAXES › Subchapter Subchapter N— Tax Based on Income From Sources Within or Without the United States › Part PART II— NONRESIDENT ALIENS AND FOREIGN CORPORATIONS › Subpart Subpart A— Nonresident Alien Individuals

26 U.S.C. § 875

Partnerships; beneficiaries of estates and trusts

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For purposes of this subtitle—(1) a nonresident alien individual or foreign corporation shall be considered as being engaged in a trade or business within the United States if the partnership of which such individual or corporation is a member is so engaged, and(2) a nonresident alien individual or foreign corporation which is a beneficiary of an estate or trust which is engaged in any trade or business within the United States shall be treated as being engaged in such trade or business within the United States.(Aug. 16, 1954, ch. 736, 68A Stat. 281; Pub. L. 89–809, title I, § 103(e)(1), Nov. 13, 1966, 80 Stat. 1551.)Editorial NotesAmendments

1966—Pub. L. 89–809 designated existing provisions as par. (1), substituted reference to nonresident alien individuals or foreign corporations for reference simply to nonresident alien individuals, and added par. (2).

Statutory Notes and Related SubsidiariesEffective Date of 1966 Amendment

Amendment by Pub. L. 89–809 applicable with respect to taxable years beginning after Dec. 31, 1966, see section 103(n)(1) of Pub. L. 89–809, set out as a note under section 871 of this title.

Notes of Decisions
Cited in 2 cases, 1984–2001 · leading case: Valentino v. Franchise Tax Bd., 105 Cal. Rptr. 2d 304 (Cal. Ct. App. 2001).
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Valentino v. Franchise Tax Bd., 105 Cal. Rptr. 2d 304 (Cal. Ct. App. 2001). “( 26 U.S.C. § 875 (1); see also Rev. Rui. 87-121, 1987- 2 C.”
Est. of Ernst N. Petschek, Deceased, Thomas H. Petschek & Asher Lans, Executors v. The Comm'r of Internal Revenue, 738 F.2d 67 (2d Cir. 1984). “business within the United States, 26 U.S.C. § 875 (2), only if the trust had received such income.”
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