Title 26, Internal Revenue CodeRelease 119-73
§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
Summary
A nonresident alien or foreign corporation counts as doing business in the United States if a partnership it belongs to does business here. The same applies if it is a beneficiary of an estate or trust that runs a trade or business in the United States.
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 26, Internal Revenue Code
Last Updated
Apr 6, 2026
Release point: 119-73