§875 — Title 26 Internal Revenue Code | U.S. Code

§875 Partnerships; Beneficiaries of Estates and Trusts

Title 26 › Subtitle Subtitle A— Income Taxes › Chapter 1— NORMAL TAXES AND SURTAXES › Subchapter N— Tax Based on Income From Sources Within or Without the United States › Part II— NONRESIDENT ALIENS AND FOREIGN CORPORATIONS › Subpart A— Nonresident Alien Individuals › § 875

Last updated Apr 5, 2026|Official source

Summary

Treats a nonresident alien individual or a foreign corporation as doing business in the United States if the partnership they are a member of is doing business here. It also treats a nonresident alien individual or a foreign corporation who is a beneficiary of an estate or trust as doing business in the United States if that estate or trust is doing business here.

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.

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.