§1443 — Foreign tax-exempt organizations

3 cases·1 questioned·2 cited

(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.

  • Treas. Reg. §Treas. Reg. §1.1443-1 Foreign tax-exempt organizations
  • Treas. Reg. §Treas. Reg. §1.1443-1(a) Income includible in computing unrelated business taxable income.
  • Treas. Reg. §Treas. Reg. §1.1443-1(b) Income subject to tax under section 4948—(1) In general.
  • Treas. Reg. §Treas. Reg. §1.1443-1(c) Effective date—(1) In general.

3 Citing Cases

Raizel Blumberger v. Ian Tilley 115 F. 4th 1113 · Cir.
Sydney Ann Chaney Thomas, Petitioner 162 T.C. No. 2 · 2024
Boyer v. Commissioner 79 T.C. 143 · 1982

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