PRIA Logo™
Title 26, Internal Revenue CodeRelease 119-110

§1443 Foreign Tax-exempt Organizations

Title 26 › Subtitle A — Income Taxes › CHAPTER 3 — WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS › Subchapter A — Nonresident Aliens and Foreign Corporations › § 1443

Last updated Sep 22, 2026|Official source

Summary

Foreign organizations taxed under section 511 must follow this chapter’s rules when figuring unrelated business taxable income for amounts they include under section 512, but only as the Secretary’s regulations allow. If a foreign organization is taxed under section 4948(a), the chapter applies too, but deductions and withholding are fixed at 4 percent and are subject to the Secretary’s rules.

Full Legal Text

Title 26, §1443

Internal Revenue Code, Source: USLM XML via OLRC

(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.

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Amendments

1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” in two places. 1969—Pub. L. 91–172, § 101(j)(22), designated existing provisions as subsec. (a) and added subsec. (b). Subsec. (a). Pub. L. 91–172, § 121(d)(2)(C), substituted “income” for “rents” after “this chapter shall apply to”.

Statutory Notes and Related Subsidiaries

Effective Date

of 1969 AmendmentAmendment by section 101(j)(22) of Pub. L. 91–172 effective Jan. 1, 1970, see section 101(k)(1) of Pub. L. 91–172, set out as an

Effective Date

note under section 4940 of this title. Amendment by section 121(d)(2)(C) of Pub. L. 91–172 applicable to taxable years beginning after Dec. 31, 1969, see section 121(g) of Pub. L. 91–172, set out as a note under section 511 of this title.

Reference

Citations & Metadata

Citation

26 U.S.C. § 1443

Title 26, Internal Revenue Code

Last Updated

Sep 22, 2026

Release point: 119-110