Title 26Internal Revenue CodeRelease 119-73

§875 Partnerships; beneficiaries of estates and trusts

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 › § 875

Last updated Apr 6, 2026|Official source

Summary

Treat a nonresident alien or a foreign corporation as doing business in the U.S. if the partnership they belong to, or the estate or trust that they benefit from, is doing business in the U.S.

Full Legal Text

Title 26, §875

Internal Revenue Code — Source: USLM XML via OLRC

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.

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Amendments

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 Subsidiaries

Effective Date

of 1966 AmendmentAmendment 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.

Reference

Citations & Metadata

Citation

26 U.S.C. § 875

Title 26Internal Revenue Code

Last Updated

Apr 6, 2026

Release point: 119-73